Support our shareholder proposal with Facebook


Given current trends in childhood obesity and the clear public health threats of over-exposure to junk food marketing, ICCR members question whether Facebook’s advertising and privacy policies adequately safeguard children and model best practices in corporate responsibility

ICCR members and shareholders in Facebook have filed a shareholder proposal with the company requesting a report that includes a risk evaluation to assess whether the scope, scale and pace of implementation of the company's advertising and privacy policies are sufficient to prevent material impacts on the company's finances and operations due to public concerns about childhood obesity and public and private initiatives to eliminate or restrict food marketing to youth.

The proposal is part of ICCR’s broader Access to Nutrition campaign which engages food, beverage, retail and media companies in order to encourage the production, promotion and access to healthier, more nutritious foods for children.

We know from studies that children are particularly susceptible to food marketing and that it has the power to shape youths’ diets.  Food marketers take full advantage of the Facebook platform and intentionally blur the lines between content and advertising by:  posting directly to “News Feeds” which appear on individual’s profiles; targeting key “influencers” and enlisting them to become “brand ambassadors”; offering prizes , sweepstakes and other incentives to “activate” users to engage with and further promote brand to their “friends”, and;  by providing sophisticated tracking and measuring tools that allow food marketers to continuously refine their strategies against these young and impressionable audiences.

ICCR members are asking Facebook to safeguard the privacy, safety and health of the youth using its site by implementing prudent policies that will prevent on-line surveillance of kids for commercial purposes and restrict messaging that doesn’t promote healthy behavior.

We offer the following as rationale for supporting this shareholder proposal:


 1. Obesity in youth remains a grave public health threat, in the U.S. and globally. According to a recent analysis by the Centers for Disease Control (CDC), teenagers’ obesity rates increased in the last decade, and the rates for children remain more than double (and for adolescents, quadruple) what they were in 1980.

2. Carrying extensive food marketing to youth, as Facebook does, exposes the company to significant and growing regulatory and reputational risks that may impact financial performance. Food marketing influences children’s food selections and diet and for this reason has been highly scrutinized by high-level officials, regulators, and civil society institutions in the last decade. For example:

  • In 2011, the American Academy of Pediatrics called for a total ban on child-targeted television and digital advertising for unhealthy foods.
  • In June 2013, the World Health Organization called for tighter controls on the marketing to children of unhealthy foods.
  • In September 2013, First Lady Michelle Obama hosted a Convening on Food Marketing to Children, urging companies from multiple sectors to do more to address the contribution of marketing to childhood obesity.

3. The food industry is spending an increasing proportion of its marketing dollars to advertise to young people on Facebook, and the company’s business model turns on revenue from such third-party advertising (84% of revenue in 2012). The Federal Trade Commission found that between 2006 and 2009, new media marketing grew 50.5%. Moreover, food and beverage marketers are among the most frequented and “liked” pages on Facebook.

 4. Facebook’s privacy policies – and the ways in which the company uses the vast amount of personal data it collects from young users for advertising – expose Facebook to financial risk from additional regulation and potential litigation.

Facebook’s current business model relies on offering marketers access to an unparalleled amount of personal data that can be used to customize messaging to young audiences. Proposed legislation, HR 3481 The Do Not Track Kids Act of 2013, calls for extensions to the current Children’s On-line Privacy Protection Act (COPPA) that would further restrict personal data collection and establish a “Digital Marketing Bill of Rights for Teens.” A group of parents has brought a lawsuit alleging that Facebook violates state laws that prohibit minors from being used in advertisements without parental consent.

5.  According to press reports, Facebook has indicated that it is considering opening its platforms to children ages 12 and under, which would greatly increase its exposure to the risks outlined above. 


If you hold Facebook shares we urge you to help protect children’s health by voting in favor of this resolution.

Our full rationale for supporting this resolution can be read here.

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