This Code of Conduct applies to all individuals and business that engage in promotional activities on behalf of Oberto or otherwise have a material connection to Oberto, including employees, agents, contractors, bloggers, celebrity endorsers, brand creator, brand ambassadors, and all other social media influencers, whether they are engaged by Oberto directly or indirectly through an agency (“Influencers” or “You”).  As an Influencer, you must clearly and prominently disclose your relationship with Oberto.  Your disclosure obligations apply equally to personal blogs, websites, social network pages or posts, and other media.

The following guidelines explain how to comply with Oberto and Federal Trade Commission requirements for making truthful endorsements.

1.  Disclose material connections with Oberto  

Who: You have a material connection to Oberto if:

  • You are paid or compensated by or on behalf of Oberto

  • You are given something for free or a discount

  • You are an employee, agent, or contractor, or are related to an employee, agent, or contractor of Oberto

  • You have any other connection that could impact the weight a person gives your opinion, including participation in the “Oberto Creator Program” or the “Oberto Influencer Program”

Media Channels: The disclosure requirement applies to any materials created, contributed, distributed, commented on, or modified by you on all media, including:

  • Social media (Facebook, Twitter, Instagram, Snapchat, Pinterest)

  • Video platforms (YouTube, Vimeo, Vine, Periscope)

  • Third-party forums and review sites (Reddit, Yelp)

  • Personal blogs and Tumblr

  • Third-party affiliate marketing sites

  • Interviews/media appearances (if not clear you are being compensated or have a relationship with Oberto)

Types of Communication:  The disclosure requirement applies to any communication that could be interpreted to promote or highlight the benefits of Oberto or its products.  The requirements can apply even if you do not actually write about Oberto (e.g., merely posting a photo showcasing an Oberto product on social media is enough).  Here are common examples where disclosure is required:

  • Communications encouraging someone to buy a product or otherwise engage with Oberto

  • Posting on social media in connection with the Oberto Creator Program or Oberto Influencer Program and/or using the #YouGetOutWhatYouPutIn or tagging @obertobeefjerky

  • Content you share from, including products and articles, as well as content you share from any Oberto social media channel

  • Sharing third-party content that is arguably favorable to Oberto such as media stories that discuss the brand

  • Content you create on your own personal blog or video site that includes information about and promotes Oberto

  • Selfies, videos, or other content prominently showcasing an Oberto product, retweeting an endorsement, or any other depiction that could be construed as promoting the brand   

2. Ensure your disclosure is clear and prominent on each post on which you endorse a product  

How to disclose:  Disclosures should be easy to see and understand.   In other words, it should be clear to the audience that you have a connection with the company.  A simple statement about your relationship is often the best option. Another option is to incorporate the disclosure into your post.  On social media you can use shorter disclosures if necessary. See below for examples of good disclosures (disclosures should be tailored to the nature of your relationship):

  • Blogs, Editorial and Product Reviews, Comments in Online Discussions

    • I am an Oberto brand influencer or I am an Oberto brand creator

    • I received free product from Oberto

    • Thanks Oberto for the free product

    • I work for Oberto

    • I was paid by Oberto

    • I am paid by Oberto for each click

  • Social Media (e.g., Twitter)

    • #ObertoInfluencer or #ObertoCreator

    • #ad

    • #sponsored

    • #promoted

    • In paid partnership with @obertobeefjerky (near the location tag on Instagram)

Location of Disclosure:  Follow these guidelines for placement of the disclosure:

  • Disclosures should be located at the beginning, next to, or on top of any applicable communication.

  • If you post a gallery of photos, product must be visible in the first visible photo. 

  • For social media, the disclosure should be in each post (e.g., #ad).

  • For video, the disclosure should appear in the video and must be on the screen for long enough to be noticed, read, and understood.  For long videos, the disclosure should be repeated. Merely including the disclosure in the description of the video is not sufficient.

  • If you cannot include or fit a disclosure in your posting, please do not use that platform.

Size of Disclosure:  The disclosure should be in large enough font for the audience to read and understand it.  The disclosure should also be visible regardless of whether viewing online or on a mobile device.  

3. Statements must reflect your honest opinions, beliefs, or experiences and must not be false, misleading, or unsupported

  • Do not make false or misleading claims about an Oberto product or service (e.g., if you thought a product was bad, don’t say it was great)

  • Do not make a claim that cannot be supported (e.g., Oberto has a particular health benefit).

  • Don’t hold yourself out as an expert if you are not one

  • If you create and distribute advertising or promotional material for Oberto, make sure that is not disguised to look like editorial, news, entertainment, or other non-advertising content

  • Ensure all product demonstrations are truthful, fair, and accurate

  • Discontinue statements if your communication is no longer true or accurate

  • Exercise caution when making conclusory or comparative statements (e.g., better than competitor)

  • Do not make false or misleading claims about a competitor’s product or service

  • Consider what the reasonable consumer would expect your message to mean, taking into account who you are, how you say it, and assuming the reasonable consumer is not well-educated or well-informed

4.  Think before you post

  • Avoid controversial or potentially damaging statements about the Oberto brand

  • Follow the relevant website’s posting requirements and terms of use

  • If applicable, state that your view is your opinion and not representative of Oberto’s view

  • Do not make, use, or distribute any offensive comments or sexually explicit material

  • Do not disparage, libel, slander, or defame any person, entity, product, or service including a competitive product or service

  • Do not promote any unsafe or illegal activities, including drugs, tobacco, alcohol, guns, or illegal gambling and wagering

  • Do not link to any content or website that violates this Code of Conduct

5. Your posts are subject to review by Oberto  

Oberto periodically reviews materials created by Influencers.  If you violate this Code of Conduct, we will remind you about your obligations and Oberto may terminate your relationship with Oberto at its discretion.