Adobe

Report March 2025

Submitted

Adobe empowers everyone, everywhere to imagine, create, and bring any digital experience to life. From creators and students to small businesses, global enterprises, and nonprofit organizations — customers choose Adobe products to ideate, collaborate, be more productive, drive business growth, and build remarkable experiences

Advertising

Commitment 1

Relevant signatories participating in ad placements commit to defund the dissemination of disinformation, and improve the policies and systems which determine the eligibility of content to be monetised, the controls for monetisation and ad placement, and the data to report on the accuracy and effectiveness of controls and services around ad placements.

We signed up to the following measures of this commitment

Measure 1.1 Measure 1.2 Measure 1.3 Measure 1.6

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

no

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

no

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 1.1

Relevant Signatories involved in the selling of advertising, inclusive of media platforms, publishers and ad tech companies, will deploy, disclose, and enforce policies with the aims of: - first avoiding the publishing and carriage of harmful Disinformation to protect the integrity of advertising supported businesses - second taking meaningful enforcement and remediation steps to avoid the placement of advertising next to Disinformation content or on sources that repeatedly violate these policies; and - third adopting measures to enable the verification of the landing / destination pages of ads and origin of ad placement.

QRE 1.1.1

Signatories will disclose and outline the policies they develop, deploy, and enforce to meet the goals of Measure 1.1 and will link to relevant public pages in their help centres.

Adobe Advertising’s Ad Requirements Policy outlines the requirement for ads to not be “false or misleading ads”, accounting for both misinformation and disinformation. In summer 2020, Adobe halted permitting political content to be distributed via Adobe’s Services. Actions taken are the following: 

(1) Research was done to locate sites that spread misinformation and disinformation by referencing 3rd party reports from Global Disinformation Index, CheckMyAds and MediaBiasFactCheck. 

(2) Flagged Sites were reviewed and verified through manual checks of 3rd party verification services such as Global Disinformation Index, Politifact, and MediaBiasFactCheck. 

(3) Domains where misinformation or disinformation was confirmed were added to the Service’s Global Blocklist. 

(4) Historical impression reports were pulled to assess the impression delivery on the domains. 

(5) Incidents found during the third period of submission have been added to the tracker. 

(6) Adobe Advertising Cloud has reached out to existing partners for consultation on available services with relevant solutions to combatting dis/misinformation. No new services have been on-boarded. 

 

Link to ads requirements policy:  https://experienceleague.adobe.com/en/docs/advertising/policies/ad-requirements-policy

SLI 1.1.1

Signatories will report, quantitatively, on actions they took to enforce each of the policies mentioned in the qualitative part of this service level indicator, at the Member State or language level. This could include, for instance, actions to remove, to block, or to otherwise restrict advertising on pages and/or domains that disseminate harmful Disinformation.

15 domains have been added to Adobe's platform blocklist. This blocklist affects all transparent open market advertising.

Country Type of Action 1 Type of Action 2 Type of Action 3 Type of Action 4
Austria 0 0 0 0
Belgium 0 0 0 0
Bulgaria 0 0 0 0
Croatia 0 0 0 0
Cyprus 0 0 0 0
Czech Republic 0 0 0 0
Denmark 0 0 0 0
Estonia 0 0 0 0
Finland 0 0 0 0
France 0 0 0 0
Germany 0 0 0 0
Greece 0 0 0 0
Hungary 0 0 0 0
Ireland 0 0 0 0
Italy 0 0 0 0
Latvia 0 0 0 0
Lithuania 0 0 0 0
Luxembourg 0 0 0 0
Malta 0 0 0 0
Netherlands 0 0 0 0
Poland 0 0 0 0
Portugal 0 0 0 0
Romania 0 0 0 0
Slovakia 0 0 0 0
Slovenia 0 0 0 0
Spain 0 0 0 0
Sweden 0 0 0 0
Iceland 0 0 0 0
Liechtenstein 0 0 0 0
Norway 0 0 0 0

Measure 1.2

Relevant Signatories responsible for the selling of advertising, inclusive of publishers, media platforms, and ad tech companies, will tighten eligibility requirements and content review processes for content monetisation and ad revenue share programmes on their services as necessary to effectively scrutinise parties and bar participation by actors who systematically post content or engage in behaviours which violate policies mentioned in Measure 1.1 that tackle Disinformation.

QRE 1.2.1

Signatories will outline their processes for reviewing, assessing, and augmenting their monetisation policies in order to scrutinise and bar participation by actors that systematically provide harmful Disinformation.

Adobe Advertising Cloud does not permit political content. Adobe Advertising Cloud is a member of The Interactive Advertising Bureau (IAB), IAB Tech Lab, Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA), European Interactive Digital Advertising Alliance (EDAA), and Trustworthy and Accountability Group (TAG).

Measure 1.3

Relevant Signatories responsible for the selling of advertising, inclusive of publishers, media platforms, and ad tech companies, will take commercial and technically feasible steps, including support for relevant third-party approaches, to give advertising buyers transparency on the placement of their advertising.

QRE 1.3.1

Signatories will report on the controls and transparency they provide to advertising buyers with regards to the placement of their ads as it relates to Measure 1.3.

1. Advertisers are able to target/block site domains or apps at the campaign placement level.

2. Advertisers are provided reporting on standard delivery metrics, primarily impression delivery, at a site domain and app level.

3. Advertisers are automatically opted into Adobe Ad Cloud’s “Global Blocklist” which includes reviewed sites and apps determined to violate policies or are determined to be inappropriate for advertising. This prevents ad delivery on those properties (1) unless the advertiser has manually opted out or (2) the advertiser has entered into a private deal exposed to or not transparent with these properties. Sites and Apps are reviewed for brand safety, invalid traffic, and ad placement.

Measure 1.6

Relevant Signatories will advance the development, improve the availability, and take practical steps to advance the use of brand safety tools and partnerships, with the following goals: - To the degree commercially viable, relevant Signatories will provide options to integrate information and analysis from source-raters, services that provide indicators of trustworthiness, fact-checkers, researchers or other relevant stakeholders providing information e.g., on the sources of Disinformation campaigns to help inform decisions on ad placement by ad buyers, namely advertisers and their agencies. - Advertisers, agencies, ad tech companies, and media platforms and publishers will take effective and reasonable steps to integrate the use of brand safety tools throughout the media planning, buying and reporting process, to avoid the placement of their advertising next to Disinformation content and/or in places or sources that repeatedly publish Disinformation. - Brand safety tool providers and rating services who categorise content and domains will provide reasonable transparency about the processes they use, insofar that they do not release commercially sensitive information or divulge trade secrets, and that they establish a mechanism for customer feedback and appeal.

QRE 1.6.1

Signatories that place ads will report on the options they provide for integration of information, indicators and analysis from source raters, services that provide indicators of trustworthiness, fact-checkers, researchers, or other relevant stakeholders providing information e.g. on the sources of Disinformation campaigns to help inform decisions on ad placement by buyers.

Adobe Ad Cloud offers several 3rd Party brand-safety targeting services that can be applied to campaign placements through our partners, with a fee. Pre-bid services halt impression delivery at the app, site or page level. These services are optional.

Commitment 2

Relevant Signatories participating in advertising commit to prevent the misuse of advertising systems to disseminate Disinformation in the form of advertising messages.

We signed up to the following measures of this commitment

Measure 2.1 Measure 2.2 Measure 2.3 Measure 2.4

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

no

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

no

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 2.1

Relevant Signatories will develop, deploy, and enforce appropriate and tailored advertising policies that address the misuse of their advertising systems for propagating harmful Disinformation in advertising messages and in the promotion of content.

QRE 2.1.1

Signatories will disclose and outline the policies they develop, deploy, and enforce to meet the goals of Measure 2.1 and will link to relevant public pages in their help centres.

Adobe Advertising Cloud’s Ad Requirements Policy clearly states that false or misleading ads are prohibited. Additionally, political content is prohibited.

SLI 2.1.1

Signatories will report, quantitatively, on actions they took to enforce each of the policies mentioned in the qualitative part of this service level indicator, at the Member State or language level. This could include, for instance, actions to remove, to block, or to otherwise restrict harmful Disinformation in advertising messages and in the promotion of content.

No advertisers have been found to violate Adobe Advertising Cloud’s Ad Requirements Policy regarding disinformation or misinformation

Country Type of Action 1 Type of Action 2 Type of Action 3 Type of Action 4
Austria 0 0 0 0
Belgium 0 0 0 0
Bulgaria 0 0 0 0
Croatia 0 0 0 0
Cyprus 0 0 0 0
Czech Republic 0 0 0 0
Denmark 0 0 0 0
Estonia 0 0 0 0
Finland 0 0 0 0
France 0 0 0 0
Germany 0 0 0 0
Greece 0 0 0 0
Hungary 0 0 0 0
Ireland 0 0 0 0
Italy 0 0 0 0
Latvia 0 0 0 0
Lithuania 0 0 0 0
Luxembourg 0 0 0 0
Malta 0 0 0 0
Netherlands 0 0 0 0
Poland 0 0 0 0
Portugal 0 0 0 0
Romania 0 0 0 0
Slovakia 0 0 0 0
Slovenia 0 0 0 0
Spain 0 0 0 0
Sweden 0 0 0 0
Iceland 0 0 0 0
Liechtenstein 0 0 0 0
Norway 0 0 0 0

Measure 2.2

Relevant Signatories will develop tools, methods, or partnerships, which may include reference to independent information sources both public and proprietary (for instance partnerships with fact-checking or source rating organisations, or services providing indicators of trustworthiness, or proprietary methods developed internally) to identify content and sources as distributing harmful Disinformation, to identify and take action on ads and promoted content that violate advertising policies regarding Disinformation mentioned in Measure 2.1.

QRE 2.2.1

Signatories will describe the tools, methods, or partnerships they use to identify content and sources that contravene policies mentioned in Measure 2.1 - while being mindful of not disclosing information that'd make it easier for malicious actors to circumvent these tools, methods, or partnerships. Signatories will specify the independent information sources involved in these tools, methods, or partnerships.

Adobe Advertising Cloud is assessing services available from current and new partners for disinformation or misinformation. This includes block lists, measurement or reporting, and pre-bid services.




Measure 2.3

Relevant Signatories will adapt their current ad verification and review systems as appropriate and commercially feasible, with the aim of preventing ads placed through or on their services that do not comply with their advertising policies in respect of Disinformation to be inclusive of advertising message, promoted content, and site landing page.

QRE 2.3.1

Signatories will describe the systems and procedures they use to ensure that ads placed through their services comply with their advertising policies as described in Measure 2.1.

Ads are scanned by 3rd party partners to determine category. Ads from categories that pertain to Adobe Advertising Cloud’s Ad Requirements Policy are flagged and reviewed for material that violates Adobe Advertising Cloud’s Ad Requirements Policy.

SLI 2.3.1

Signatories will report quantitatively, at the Member State level, on the ads removed or prohibited from their services using procedures outlined in Measure 2.3. In the event of ads successfully removed, parties should report on the reach of violatory content and advertising.

No ads were removed for violations of Adobe Advertising Cloud’s advertising policy related to disinformation or misinformation.

Country Nr of ads removed (as well as reach of ads before they were successfully removed) Nr of ads prohibited
Austria 0 0
Belgium 0 0
Bulgaria 0 0
Croatia 0 0
Cyprus 0 0
Czech Republic 0 0
Denmark 0 0
Estonia 0 0
Finland 0 0
France 0 0
Germany 0 0
Greece 0 0
Hungary 0 0
Ireland 0 0
Italy 0 0
Latvia 0 0
Lithuania 0 0
Luxembourg 0 0
Malta 0 0
Netherlands 0 0
Poland 0 0
Portugal 0 0
Romania 0 0
Slovakia 0 0
Slovenia 0 0
Spain 0 0
Sweden 0 0
Iceland 0 0
Liechtenstein 0 0
Norway 0 0

Measure 2.4

Relevant Signatories will provide relevant information to advertisers about which advertising policies have been violated when they reject or remove ads violating policies described in Measure 2.1 above or disable advertising accounts in application of these policies and clarify their procedures for appeal.

QRE 2.4.1

Signatories will describe how they provide information to advertisers about advertising policies they have violated and how advertisers can appeal these policies.

If an advertiser is found to violate Adobe’s Ads Requirements Policy, they are notified via email. This notice includes the specific ad in violation, the policy it violates, and a link to Adobe’s Ads Requirements Policy. They are also notified that three violations may result in removal from the platform. Advertisers can appeal this process and be subject to a 90 day grace period to be reviewed if any additional violations are levied against them. The strikes may be removed after these conditions are met.

SLI 2.4.1

Signatories will report quantitatively, at the Member State level, on the number of appeals per their standard procedures they received from advertisers on the application of their policies and on the proportion of these appeals that led to a change of the initial policy decision.

Nr of appeals: 0

Country Nr of appeals Proportion of appeals that led to a change of the initial decision
Austria 0 0
Belgium 0 0
Bulgaria 0 0
Croatia 0 0
Cyprus 0 0
Czech Republic 0 0
Denmark 0 0
Estonia 0 0
Finland 0 0
France 0 0
Germany 0 0
Greece 0 0
Hungary 0 0
Ireland 0 0
Italy 0 0
Latvia 0 0
Lithuania 0 0
Luxembourg 0 0
Malta 0 0
Netherlands 0 0
Poland 0 0
Portugal 0 0
Romania 0 0
Slovakia 0 0
Slovenia 0 0
Spain 0 0
Sweden 0 0
Iceland 0 0
Liechtenstein 0 0
Norway 0 0

Commitment 3

Relevant Signatories involved in buying, selling and placing digital advertising commit to exchange best practices and strengthen cooperation with relevant players, expanding to organisations active in the online monetisation value chain, such as online e-payment services, e-commerce platforms and relevant crowd-funding/donation systems, with the aim to increase the effectiveness of scrutiny of ad placements on their own services.

We signed up to the following measures of this commitment

Measure 3.1 Measure 3.2 Measure 3.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

no

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

no

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 3.1

Relevant Signatories will cooperate with platforms, advertising supply chain players, source-rating services, services that provide indicators of trustworthiness, fact-checking organisations, advertisers and any other actors active in the online monetisation value chain, to facilitate the integration and flow of information, in particular information relevant for tackling purveyors of harmful Disinformation, in full respect of all relevant data protection rules and confidentiality agreements.

QRE 3.1.1

Signatories will outline how they work with others across industry and civil society to facilitate the flow of information that may be relevant for tackling purveyors of harmful Disinformation.

Adobe Advertising Cloud has partnerships with various 3rd party brand safety solution providers to offer targeting and reporting. Some have available targeting related to disinformation and misinformation. Adobe Advertising Cloud cooperates with supply partnerships to block any apps, sites, or sellers that are found to have disinformation and misinformation. Adobe Ad Cloud also reviews publicly available reports through reputable journals or news articles establishing specific acts of disinformation or misinformation.

Measure 3.2

Relevant Signatories will exchange among themselves information on Disinformation trends and TTPs (Tactics, Techniques, and Procedures), via the Code Task-force, GARM, IAB Europe, or other relevant fora. This will include sharing insights on new techniques or threats observed by Relevant Signatories, discussing case studies, and other means of improving capabilities and steps to help remove Disinformation across the advertising supply chain - potentially including real-time technical capabilities.

QRE 3.2.1

Signatories will report on their discussions within fora mentioned in Measure 3.2, being mindful of not disclosing information that is confidential and/or that may be used by malicious actors to circumvent the defences set by Signatories and others across the advertising supply chain. This could include, for instance, information about the fora Signatories engaged in; about the kinds of information they shared; and about the learnings they derived from these exchanges.

Adobe Advertising Cloud has had discussions with multiple 3rd party Brand Safety and Cybersecurity providers, exploring capabilities to target away from or block sites that host disinformation or misinformation.

Measure 3.3

Relevant Signatories will integrate the work of or collaborate with relevant third-party organisations, such as independent source-rating services, services that provide indicators of trustworthiness, fact-checkers, researchers, or open-source investigators, in order to reduce monetisation of Disinformation and avoid the dissemination of advertising containing Disinformation.

QRE 3.3.1

Signatories will report on the collaborations and integrations relevant to their work with organisations mentioned.

Adobe Advertising Cloud has integrated at least 15 domains found on publicly available reports to demonetise distributors of dis/misinformation.

Monitoring of the Code

Commitment 38

The Signatories commit to dedicate adequate financial and human resources and put in place appropriate internal processes to ensure the implementation of their commitments under the Code.

We signed up to the following measures of this commitment

Measure 38.1

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 38.1

Relevant Signatories will outline the teams and internal processes they have in place, per service, to comply with the Code in order to achieve full coverage across the Member States and the languages of the EU.

QRE 38.1.1

Relevant Signatories will outline the teams and internal processes they have in place, per service, to comply with the Code in order to achieve full coverage across the Member States and the languages of the EU.

Adobe has an EU Code of Practice Tiger Team, which is an internal, cross-functional team that meets regularly to discuss the implementation of the Code commitments and our reporting requirements. This work is overseen by the General Counsel.

Commitment 39

Signatories commit to provide to the European Commission, within 1 month after the end of the implementation period (6 months after this Code’s signature) the baseline reports as set out in the Preamble.

We signed up to the following measures of this commitment

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Commitment 41

Signatories commit to work within the Task-force towards developing Structural Indicators, and publish a first set of them within 9 months from the signature of this Code; and to publish an initial measurement alongside their first full report.

We signed up to the following measures of this commitment

Measure 41.1 Measure 41.2 Measure 41.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

no

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

no

If yes, which further implementation measures do you plan to put in place in the next 6 months?