DSSRC Administrative Closure #24

DSSRC inquired into a two product claims disseminated on Facebook by a distributor for a multi-level direct selling company. DSSRC expressed its concern that the social media posts conveyed unsubstantiated product claims that the Company’s products can protect against disease and the COVID-19 virus.

The Company informed DSSRC before this inquiry had been commenced that it had already initiated action against both cited violations and was successful in having one of them taken down around the same time as DSSRC’s notification was received.

The Company stated that the second post was made by an international salesforce member who was promptly suspended in September 2019 after failure to take requested actions and that it attempted to reach out again using the assistance of a local upline member, as well as contacting Facebook to report the page and seek removal of the claim. The Company explained to DSSRC that it has developed an active, daily monitoring approach to address compliance matters and that this team not only monitors daily compliance matters but is also dedicated to educating and enforcing the requirements of its Distributor Agreement and Policies and Procedures.

The Company also noted that it has been working with a third party monitoring vendor to assist in its field compliance monitoring and to further engage its members in compliance training and informed DSSRC that all company-produced business opportunity and product marketing materials, video content and website copy are reviewed by a third-party food and drug law and regulation attorney for compliance purposes before publication. 

Based upon the good faith efforts exercised by the Company to have the unauthorized posts removed, DSSRC administratively closed the inquiry. 

(closed on 5/5/2020)