Tessa Jowell, secretary of state for culture, media and sport, this week delivers the keynote address at the annual conference of the Incorporated Society of British Advertisers (ISBA), outlining what she thinks the government expects of advertisers.
Her speech comes at a crucial time, with advertisers at the eye of the storm currently raging over obesity, and the government under pressure to restrict, or even ban, the promotion of junk food to children.
So, when Jowell talks about the government's expectations of advertisers, many in the industry are keen for a glimpse inside her mind. Does she hold advertisers responsible for the problem and intend to punish them, or does she want to work with the industry to find a solution?
And it is not just the food and drink marketers that hang on her every word. Brand owners in the alcohol, automotive and data-marketing fields are also wary, knowing that the spotlight, which has shifted from tobacco to food, could easily move on to their sectors next.
For companies involved in any of these fields, now is the crucial time not only to gain a clear understanding of government policy and any proposed changes in the pipeline, but also to try to manoeuvre themselves into the decision-making process. Whether this is through trade associations, public affairs consultancies or direct contact, it has never been more important for marketing-led companies to be plugged into the government machine.
It is no easy task for food and soft-drinks firms to ensure they are up to speed with the obesity debate, involving as it does a multitude of single-issue pressure groups, government departments, committees, and individual campaigning MPs and MEPs.
Anyone believing the most important thing is to have a clear understanding of, or relationship with, Ofcom - the super-regulator with overall responsibility for broadcast advertising standards - should think again. Although Ofcom will be very important for advertisers, they need to ensure its links with the government run deeper, as policy may be developed elsewhere and then passed on to Ofcom for implementation.
As Dave Hudson, commercial director of Nestle UK, which spends more than £65m a year on advertising, says: "I cannot remember an issue so complicated, involving so many government agencies. Obviously, pressure is building and not only in the UK. The World Health Organisation is also looking into obesity and is due to report in May."
Perhaps not wanting to antagonise the government at such a sensitive time, the food and soft-drinks industry outwardly claims that Jowell is taking a sensible approach. As Hudson explains: "Our message to government is 'please include the food industry in the debate' and Jowell has said in the past that she doesn't want to paint us into a corner. We're not complacent; we know we have powerful brands, we understand our responsibilities and we want to be part of developing solutions."
Wide-ranging opinion
Andrew Marsden, category director at Britvic Soft Drinks is aware of the hard line being taken by MPs such as Debra Shipley, a member of the culture, media and sport committee, which wants to ban all advertising for foods high in fat, sugar and salt from children's TV. But he is hopeful that the government is prepared to talk constructively with advertisers.
"There is clearly a wide range of opinion within government and a lot of senior ministers have said this is not an issue about advertising alone," says Marsden. "Jowell progressively understands the nature of the problem, although some members of her party are being aggressive and taking a stance they know will grab headlines. Thankfully, there are some wise politicians around who know this is a debate about the nation's health and not about what should and should not be advertised."
As delegates at the ISBA event eye Jowell, they may wonder how they can win her ear, or that of anyone influential in government. So if it is more important than ever to forge an open channel of communication, how can marketers achieve it?
The first port of call is clearly the trade associations, which can lobby on behalf of their members. Although ISBA and the Advertising Association (AA) have a lead role to play in the obesity debate, they are backed by food-specific groups such as the Food and Drink Federation and the Food Advertising Unit. Meanwhile, in other industry sectors, there are specific bodies to deal with issues. These include The Portman Group, which represents drinks firms, and the Society of Motor Manufacturers and Traders.
"ISBA is becoming more and more effective, and it is clear that the government is open to listening to the voice of the advertising industry," says Paul Philpott, commercial director at Toyota (GB). "The best way for advertisers to lobby government is through ISBA, but it can only get stronger with an active membership. Too few advertisers are engaged in setting codes of practice for the future and, as far as the car industry is concerned, I am disappointed that more manufacturers are not actively involved with ISBA."
Lines of communication
So, although trade associations can be a powerful means of being heard in Whitehall, they have their drawbacks. As Lee Findell, account director at Weber Shandwick, which conducts public affairs work for clients including Nestle, points out: "Trade bodies are a great fount of information, and they live and breathe the key policy issues affecting their members. The downside is that they can only move as fast as their slowest member."
He adds: "If they have members reluctant to lend their voice to an issue, they can find it hard to move quickly. Bigger companies may sometimes find they have to step out and make the running for themselves."
This means companies may have to establish a second channel of communication with government, which is often conducted at a higher level. Clearly, the bigger the company, the more clout its voice can carry.
Drinks company Diageo has found it can win the ear of government by taking a two-pronged approach. "You need to talk to government through the trade associations and directly," says Diageo corporate affairs director Tony Mair. "The government often wants to hear from individual companies as it can get an exclusive view, compared with the generic one it receives from a trade association."
He adds: "It also knows we spend a lot on research and often understand consumer trends better than a trade body. We have been invited to consult with the Downing Street Strategy Unit (which is preparing an alcohol harm-reduction strategy) and have arranged meetings ourselves. We have found the government is reasonably open to dialogue."
The problem with this approach is that it is limited to the influential minority and fails to present the government with the unified force of a collective voice.
Britvic's Marsden advises against going it alone and says his company allows the AA and ISBA to lead the charge on its behalf. "They are the representative bodies and I don't think our cause is helped by lots of people doing their own thing. It sometimes puts the wrong issue into the spotlight. This is an important subject and needs to be treated as such. When you have everyone whizzing around, trying to push their own particular angle, the arguments can become more and more obscure."
Perhaps the best advice for advertisers is, as Corporal Jones said to Captain Mainwaring in Dad's Army, "Don't panic". Despite the calls for stiffer controls over advertising, the government shows no sign of abandoning the UK's long-established and largely effective system of self-regulation.
Ofcom has been established in part to offer a more flexible system for a new regulatory landscape. But having said that, the industry is under attack and much work is required by advertisers to defend their position.
However, as the AA's director-general, Andrew Brown, points out, this is a challenge, not an insurmountable problem. "Advertising is clearly under the microscope," he says. "And it is for the industry to respond and promote its position as part of a broader-based solution."
THE AD AGENCY MAN
Andrew Brown, Director-general, Advertising Association
Government expectations of the way the industry behaves are high, but I don't think it is coming down heavier on advertising. As we're seeing with the obesity debate, it is wrestling with real societal problems, of which advertising may be a component part.
I think the government is genuinely looking for evidence-based decision-making and is not being panicked into making advertising a scapegoat.
Yes, advertising is on the government agenda in the context of food and it's likely that the same will soon be true for alcohol, but that doesn't mean it is looking to hold advertising responsible. It is looking for broad, effective solutions to social problems, and wants advertising to be part of it.
The ad industry can't say 'this has nothing to do with us'. We are part of the marketing of goods and services and should expect to be examined. We must accept that the standards by which we behave should meet society's needs and not undermine them.
We operate in a landscape where advertising is bound to be on many agendas. Therefore, any advertiser, not only multinational companies, needs to have a finger on the pulse of the way regulators and political institutions are debating some of the interests affecting their business.
It is important trade associations, such as the AA and ISBA, are grown up and evidence-based, and avoid the rhetoric, tit for tat and slagging off that goes on when debating these highly emotionally charged issues.
We should try to provide government with evidence that enables enlightened policy, not knee-jerk reaction.
THE REGULATOR
Tim Suter, Partner, content and standards, Ofcom
Ofcom's role in relation to broad-cast advertising remains broadly the same as that of the former ITC, BSC and Radio Authority.
In the short term, we are operating from the same broadcast advertising codes. However, Parliament has charged us with being a 'light-touch' regulator, as well as requiring us to seek opportunities for co-regulation, where practical. Ofcom has therefore proposed to contract out advertising regulation to a new co-regulatory system under the banner of the Advertising Standards Authority (ASA).
An extensive public consultation has just ended and if the proposals are implemented, the ownership and enforcement of the Advertising Codes, as well as the handling of all advertising complaints, will pass to the ASA, with Ofcom retaining back-stop powers.
Ofcom believes that placing the regulation of advertising - broadcast and non-broadcast - under one roof will benefit consumers by providing a one-stop shop for complaints. Also, a single advertising regulator should be in the best position to tackle advertising issues arising from digital convergence.
On a separate issue, we are currently conducting a wide-ranging research programme into the impact of food promotion to children. We will seek the views of children, parents, teachers and professionals on this important social issue. As part of this review, we'll also examine and assess the University of Strathclyde's report, prepared for the Food Standards Agency, on the effect of food promotion to children.
We will draw the results together to determine whether there is evidence to suggest the broadcast adver-tising codes need changing.
THE VOICE OF ADVERTISERS
Malcolm Earnshaw (centre) Director-general, ISBA
The government expects self-responsibility from advertisers. This can best be exhibited via support for the UK self-regulatory system, and respect for the spirit and letter of its codes. Initiatives such as Media Smart, the educational programme for ensuring children understand the role of advertising, provide opportunities to underline our self-responsibility.
In return for self-responsibility, we ask government to respect the value of commercial communications to our society, as consumer information and a key driver of competition and economic growth. We ask that it doesn't make simplistic assumptions that over-estimate the persuasive power of advertising, or use threats of banning advertising as political tools to 'be seen to be doing something'.
The government respects a clear, collective voice. The views of even the largest advertisers are heard better when they speak as one; hence ISBA.
ISBA enjoys good relations with politicians, civil servants and government agencies. And we have had considerable success in ensuring our members' views are recognised in government policy.
Where there is a common industry position, ISBA works through the AA, which represents us, media firms and communications agencies.
At EU level, ISBA works with the World Federation of Advertisers. Decisions that are taken in Brussels are having an increasing impact on UK advertisers, so strong representation at this level is crucial. We are confident that we will continue to be given access to decision-makers and that our views will continue to be heard.
.jpg)
.jpg)