If you are trying to inform or train your employees about the product in order to offer it to non-employees, and not to sell it to the employees, it's not an ad. But if your intent is to promote the product to your employees, it's an ad, and there isn't an exception you can use.
If it's truly an ad, why would you not want to treat your employees as well as you would the public? They are consumers, too, after all.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8