Cute kids, but should a magazine's cover be the prize in a sponsored contest?

Among the key provisions in the Canadian Magazine Industry Code of Reader & Advertiser Engagement is that

No advertisement may be promoted on the cover of the magazine or included in the editorial table of contents, unless it involves an editorially directed contest, promotion or sponsored one-off editorial extra.

and

An advertiser's name or logo may not be used to suggest advertising sponsorship of any regularly appearing editorial. Nor shall any regularly appearing editorial be labelled as “sponsored” (or “brought to you by” or any other variation thereof) by an advertiser. Sponsorship language may only be used with one-off editorial extras, such as special features, sections, contests, stand-alone brand extensions, inserts and onserts, provided the editorial content of the editorial extra does not mention or endorse the advertiser (and the advertiser does not have input in the creation of the editorial).

The publishers of Today's Parent magazine (Rogers Publishing Limited) are skating awfully close to offending the spirit of those provisions with its competition to pick one child to appear as a cover model in its September issue, a competition sponsored by and paid for ("Presented by") Loblaws-owned fashion line Joe Fresh. The contest, which accepted entries through March 30 and now allows readers to vote for their favourite child during April, results in  picking four finalists. They and a parent are flown to Toronto for a photo shoot, are put up at a hotel and receive Joe Fresh gift cards;  $250 for the three runners-up; $500 for the winning cover model.

Joe Fresh or Loblaws has no role in picking the winner, thereby dictating the magazine's cover, which is the only reason this is not an absolutely clear-cut case. We're reasonably sure that Today's Parent characterize this as an "editorially directed contest". 

But one has to wonder whether the spirit of the guidelines, intended, among other things, to preserve the editorial integrity of covers, is broken when the cover itself becomes the prize in a contest.

[Disclosure: I sat on the committee which drew up the ad-edit guidelines.]