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Sponsorship and Advertising Frequently Asked Questions

1.  Who is authorized to sell sponsorship and advertising on the installation?

Only MWR sponsorship and advertising personnel who have received annual sponsorship training; attended ethics training; and who have been appointed in writing by an authorized installation command representative (such as the DCA/MWR Director) and who have a signed designation letter on file with the FMWRC are authorized to solicit and sell on behalf of Army MWR programs and events.

 

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2.  Which programs are MWR sponsorship and advertising managers authorized to sell?

Only bonafide MWR programs and events as recognized by AR215-1 may be sponsored or display advertisements and benefit from Commercial Sponsorship or Advertising.  Refer to figure 3-1 MWR Programs, Section II Funding Categories in AR 215-1 for a list of MWR activities.  However, the Department of Defense has permitted sponsorship for three non-MWR programs:  Army Family Team Building (AFTB); Army Family Action Plan (AFAP); and Army Community Services (ACS).  Note that this permission is limited to the NAF funded portion of the programs and only when the use of APFs is not authorized.  Expenditures of NAF are authorized only where APF is not authorized. 

 

MWR sponsorship managers may not solicit sponsorship on behalf of private organizations; or installation events that are not conducted by MWR.  For example, an MWR sponsorship manager is not allowed to seek sponsorship for private organizations such as AUSA; the Officers’ and Civilians’ Wives’ Club; Boy Scouts; or a Toastmasters Club.  In addition, just because a private organization or installation entity hosts an event at an MWR facility does not qualify it as an MWR event, nor does it make the event eligible for MWR sponsorship.

 

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3.  May a private organization (PO) sell sponsorship?

A PO can raise funds on the installation in accordance with local guidance and consistent with the purpose statement contained in their charter, as approved by the SJA office.  A PO can raise funds or obtain cash or donated  products through solicitation of businesses outside the gate (unfortunately, in competition with your MWR efforts, but perfectly OK), but can not promise advertising exposure or public recognition on the installation to that business beyond the POs membership or outside of the activity for which the solicitation is supporting.  POs cannot conduct or compete with MWR events and, therefore, cannot solicit donations or sponsorship on behalf of MWR events, nor can they misrepresent their affiliation/relationship with the installation in such a manner that the business believes that it is the installation and not a PO that is soliciting.  POs and units may conduct a resale activity at an MWR event as prescribed in chapter 13-18 a., AR 215-1.

 

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4.  What type of companies should not be solicited for sponsorship?

  • Off-post financial institutions defined as banks, credit unions, and savings and loan institutions when there is an existing on-post financial institution
  • Alcohol and tobacco companies (we can work with alcohol and tobacco companies, however offers must be unsolicited)
  • Companies on your installation’s off-limits list
  • Companies on the Army banned list of sources
  • Generally companies that are not focused on consumer products (i.e. business to business, government contractors)
  • Firms in direct competition with AAFES; Commissary; or other Army/DoD activities

5.  What are the sponsorship rules regarding alcohol sponsorships?

Alcohol sponsorships must be unsolicited.  Please reference AR215-1, chapter 11-11 b. for additional information.  Also, remember that the local command has the final say as to as whether or not alcohol or any commercial sponsor or advertiser is accepted on an Army installation. 

 

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6.  May an MWR sponsorship manager sell advertising and sponsorship to banks and credit unions?

Yes, but only to on-post financial institutions (banks, credit unions or savings and loans.)  On-post banks and credit unions are granted a certain level of protection from competition by DoD Directive 1000.11.  If there is no on-post financial institution, solicitation is permissible.

 

Promotions focusing around the Chase/Bank One Army MWR Club Card Program, or the AAFES charge card are permissible.

 

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7.  Where can I find a list of off-limits sponsors and advertisers?

A list of off-limits companies can normally be found at the installation’s Consumer Affairs Office; Provost Marshal’s office; or the SJA office.

 

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8.  What type of companies should be targeted to sponsor MWR events?

Preference should generally be given to companies that offer consumer products and services.  Although it is not prohibited to work with government contractors or companies focused on business-to-business initiatives on a limited basis under certain narrow circumstances, advance consultation with the installation Staff Judge Advocate office is advised prior to solicitation.

 

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9.  Can an MWR sponsorship and advertising manager solicit sponsorship and/or advertising for FRGs?

No. As an official program of the Department of the Army, FRG mission activities must be supported using appropriated funds (APF) to the same extent as any other Commander’s program.  The FRG is not a Morale Welfare and Recreation activity.  FRG activities authorized APFs may not be supported with non-appropriated funds.  In accordance with DoDI 1015.10, Programs for Military Morale, Welfare, and Recreation, and AR 215-1, commercial sponsorship is generally only authorized for official MWR programs and events.

 

FRGs are not established for the purpose of being a fund-raising organization and they have no authority to engage in external fundraising on or off post.

 

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10.  Can an MWR sponsorship and advertising manager solicit for or accept donations?  How do donations differ from sponsorships?

Employees of the government (military and civilian) cannot solicit donations or gifts.  MWR sponsorship and advertising managers should not solicit for donations.  The Joint Ethics Regulation addresses this issue and you should consult with your legal advisor when you have questions. 

 

Regarding the acceptance of unsolicited donations, some donation offers might be useful to an MWR program or event.  In this case, the offeror should be re-directed to the DCA or MWR chief for consideration of a gift to MWR per chapter 13-14 in AR 215-1.  If the gift offer does not support or contribute to the MWR mission, the offeror should be re-directed to the Garrison Commander for consideration as a gift to the Army or as a gift to individual soldiers (AR 1-100, AR 1-101, respectively.)

 

Sponsorship differs from donations as sponsorship agreements provide companies with an exchange of value by providing marketing benefits and promotional exposure.  Donations must be unsolicited and do not provide any form of marketing or promotional exposure.  In some instances a company inquiring about a donation might be interested in receiving exposure or other sponsorship benefits in exchange for the gift.  In this case, the offer may develop into a commercial sponsorship agreement. 

 

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11.  What is the sponsorship and advertising coordination requirement with the local JAG/SJA office?

Working with the local JAG office on installation sponsorship and advertising program is required to ensure proper compliance with Army regulations.  All sponsorship and advertising agreements must be legally approved by the installation JAG office or legal counsel prior to submission to a client. 

 

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12.  What disclaimers are necessary for MWR and sponsor advertising and promotional materials?

Sponsorship disclaimers, such as, “No official U.S. Army endorsement is implied,” must be included on all print materials containing sponsor recognition of any kind.  For alcohol sponsorships, a responsible use campaign such as “Please Drink Responsibly” must also be included.  Please use the appropriate disclaimers that have been legally approved by your local JAG office. 

 

Printed materials provided by sponsors for use in conjunction with an MWR program or event, should incorporate appropriate sponsorship disclaimers into the sponsors’ printed materials. 

 

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13.  How should sponsorship and advertising revenue and expenses be recorded?

Sponsorship revenue is recorded in GLAC 553 and advertising revenue is recorded in GLAC 557.  Installation financial managers follow the NAF  Financial Management Operating Guidance.  

 

 

Working with your installation Financial Management department is vital to monitoring and accurately reporting sponsorship and advertising revenue and expenses.  

 

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14.  May Army MWR Sponsorship managers sell sponsorship for officially hosted command sponsored events (reference chapter 5-14 i., AR 215-1)?

No.  Installation or command sponsored events such as change of command, retirement ceremonies, and unit social functions that are not MWR events may not receive benefits from the MWR commercial sponsorship program.

 

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15.  May personal data collected from attendees of an MWR event be passed along to or collected by an MWR event sponsor?

No, except when the individual has specifically authorized the release of such information in writing.  The attendee could fill out a request for information card, if such a benefit is provided the sponsor, or in the case of an authorized sweepstakes, the entry form could include an “opt-in” box which the attendee could elect to check, thereby authorizing/requesting additional information or requesting to be contacted by the sponsor. 

 

An example of an opt-in clause is:  Yes, I wish to receive additional information regarding the sponsor’s line of products. 

 

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16.  Are sponsors authorized to conduct sales at the MWR event that they are sponsoring?

No.  For example, a car dealership could be permitted to display vehicles and discuss vehicle features with interested patrons; however, the dealer could not at any time discuss financing options, nor conduct negotiations of any kind. 

 

The installation could choose to permit vendors to sell merchandise at the MWR event.  NAF contracting procedures must be followed and NAF concessionaire contracts would be required. 

 

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17.  Can MWR Sponsorship and Advertising Managers enter into Commercial Sponsorship or Advertising agreements with competitors of AAFES (e.g. Walmart, Target, etc.)? 

No, unless AAFES has concurred.  The sale of sponsorship and advertising to retail stores and competitors of AAFES is strongly discouraged.  MWR should respect the strategic business relationship it has with AAFES since MWR receives a dividend of the profits generated by AAFES, MWR’s strategic business partner.  Per DoDI 1015.1 and AR 215-1, advance coordination of proposed MWR sponsorships with AAFES is required.  MWR should advise AAFES management of commercial sponsorship proposals and agreements to ensure that such agreements do not violate existing AAFES policy, understandings or agreements.

 

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18.  Can MWR sponsorship and advertising managers sell advertising or commercial sponsorship opportunities to competitors of DeCA (commissary)?

This is highly discouraged.  Caution should be taken when soliciting sponsorship or advertising support from DeCA competitors such as off-post grocery stores.  DeCA saves authorized patrons approximately 30% per year in grocery bills, a benefit that is invaluable to military personnel and retirees.  If MWR partners with local supermarkets, this may lead to declining sales for DeCA and might adversely impact DeCA’s overall level of cooperation and MWR support.  There may be instances where MWR would like to solicit for gift certificates or free products from grocery stores to enhance an event.  The benefits from receiving this type of support from off-post retailers should be compared to the potential negative backlash that MWR may receive from DeCA.   Therefore, the sale of advertising and sponsorship to retail stores and grocery chains is strongly discouraged.

 

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19.  Can MWR sponsorship and advertising managers sell advertising or commercial sponsorship opportunities to local cellular phone service providers?  (e.g. Cingular, Verizon Wireless, T-Mobile, Nextel, etc.)

MWR sponsorship and advertising managers should work with AAFES on a local level to determine which cellular provider has a contract with the local AAFES store.  MWR should not work with competitors of the local cellular phone service provider.

 

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20.  Can MWR sponsorship and advertising managers solicit sponsorship from AAFES or DeCA?

No.  AAFES gives MWR dividends on a yearly basis which totalled over $120 million in FY05.  AAFES operates under Department of the Army and Department of Defense regulations.

 

DeCa is a government agency that is funded by Congress with appropriated funds.  Neither AAFES nor DeCa are in a position to sponsor MWR programs but often times support the sponsorship and advertising program by allowing us to have displays in their stores if one of their vendors sponsors our events.

 

In rare occasions a local AAFES or DeCa manager has provided items to MWR for a specific event.  These items were promotional items that were received from their vendors.  Since AAFES is bound by the same policies as MWR, their managers are not permitted to solicit for donations.

 

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21.  Can MWR sponsorship and advertising managers enter into agreements, where sponsors/advertisers provide score boards and similar items and in return receive the right to sell advertising on the score boards via a sponsorship/advertising agreement? 

No.  Such agreements should be negotiated through NAF Contracting only.  By entering in such agreements the installation might lose potential advertising income that could be obtained by the MWR sponsorship and advertising manager. 

 

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22.  Can foreign car companies sponsor MWR programs and events overseas?

No.  The military exchange systems have sole authority for the sale of new and factory certified program automobiles on DoD installations overseas.  Accordingly, it is DoD and Army policy that no other activity, instrumentality, or private organization may publicize, display or sell automobiles.  Because it is inherent in the commercial sponsorship agreement to publicize and display the product of the sponsoring commercial vendor, the MWR NAFI may not undertake such agreements with other than exchange car sales agencies.  Thus, the AAFES exchange car sales agency (Exchange New Car Sales) may be solicited as a sponsor or advertiser. 

 

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23.  What are the regulations I need as a sponsorship and advertising manager?

There are several regulations that Army MWR sponsorship and advertising managers must follow.  Please become familiar with the following regulations as related to sponsorship and advertising.

 

Department of Defense and Army Regulations for the Installation Sponsorship and Advertising Manager

Army Regulation 215-1   -  

Morale, Welfare, and Recreation Activities and Non-Appropriated Fund Instrumentalities

  • Chapter 11, Para 11-1      MWR Advertising
  • Chapter 11, Para 11-6      Commercial Sponsorship
  • Chapter 13, Para 18      Events
  • Chapter 8, Para 8-26      Raffles
  • Chapter 13, Para 14      Acceptance of Gifts and Donations

http://www.usapa.army.mil/pdffiles/r215_1.pdf

 

Department of Defense Instruction (DoDI) 1015.10                                                     

Program for Military Morale, Welfare and Recreation

  • Enclosure 9 Sponsorship
  • Enclosure 10 Advertising

http://www.dtic.mil/whs/directives/corres/pdf/101510p.pdf

 

NAF FY08 Financial Management Operating Guidance

  • Enclosure 5 – 31. Commercial Sponsorship and Advertising
  • Enclosure 7 – Matrices

http://www.army.mil/cfsc/documents/fm/opguide08/encl5.doc#sponsorship

 

Excluded Parties List -

Companies excluded from doing business with the Government           

http://www.epls.gov/

 

DoD Financial Management Regulation, Volume 5, Chapter 34, paragraph 340403- Advertising-

Advertising as related to financial institutions

http://www.defenselink.mil/comptroller/fmr/05/05_34.pdf

 

Additional regulations for reference: 

DOD 5500.7-R  -  The Joint Ethics Regulation (JER)

http://www.dod.mil/dodgc/defense_ethics/ethics_regulation/jer1-6.doc

 

Army Regulation 210-22  -   Private Organizations on Department of the Army Installations

  • Chapter 3, para 1, b-(3)

http://www.apd.army.mil/pdffiles/r210_22.pdf

 

Army Regulation 1-100   -   Gifts and Donations

http://www.apd.army.mil/pdffiles/r1_100.pdf

 

Army Regulation 1-101   -   Gifts for Distribution to Individuals

http://www.apd.army.mil/pdffiles/r1_101.pdf

 

Army Regulation 25-52 -  Authorized Abbreviations, Brevity Codes, and Acronyms

http://www.apd.army.mil/pdffiles/r25_52.pdf

 

Wednesday, January 4, 2012
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