What is responsible marketing?
When I started working on this long time ago, we used to go to talk to the WHO [World Health Organisation] about food advertising in the framework of the debate on diet, physical activity and health. We talked about ‘responsible food marketing’, but at that time we had not articulated in a clear, coherent and understandable manner what we meant by that. The WHO told us that they didn’t exactly understand what we meant by ‘responsibility’ in practical terms
So we took a blank sheet of paper, sat down and asked ourselves what we meant by responsibility in terms of food marketing. We listened to other stakeholders – NGOs, regulators, parents, teachers, consumer groups – and they told us that it is not only about how you advertise – the marketing techniques used – but it is also about what you advertise, so quantitative and qualitative restrictions. So we needed to come up with a vision of responsibility in terms of responding to those two dimensions.
This means that we needed to put in place codes of conduct globally to ensure that marketers are advertising responsibly in terms of the marketing techniques that they are using. In practical terms this means that they are not appealing directly to children and trying to undermine parental authority; that they are not promoting unhealthy lifestyles; that they don’t insinuate that crisps or chocolate could replace meals; and so on.
Furthermore, stakeholders told us that another problem was perceived to be that children were watching an advert for chocolate, followed by an advert for a burger, followed by an advert for a sugary soft drink, etc. And it was the ‘cumulative effect’ that is supposedly impacting children’s food choices and food preferences. This meant that we needed to adopt a self-regulatory scheme to change the types of products that were being promoted to children. So, it is not only about howyou advertise but also about what you advertise.
In 2007 we got an agreement between 11 companies not to advertise to children under 12 years old - except ‘better for you’ products. For example, Kraft Foods, Nestlé, Unilever, Kellogg’s and others only advertise some of their products to children, which fulfil strict nutritional criteria.
Others, such as Coca-Cola, Ferrero and Mars, have stopped all advertising to under 12s. These companies, accounting for about 66% of all food advertising business in the EU, made this big commitment – which de facto changed the types of products advertised to children.
So when you ask what is ‘responsible’ – it is putting together, across the whole of industry, standards on what you can, and more importantly, cannot do in your advertisements and then companies themselves are committing to advertising only ‘better for you’ products to children.
Is it responsible to advertise to children at all?
Let me turn the question around. Today in the environment we live in, how do you try and pretend not to advertise to children, or how do you try to shelter children from advertising?
Sweden has tried to ban advertising on TV for under 12s – but what does it mean, not to advertise to children? Children watch TV at any time of the day and are always on the Internet. They walk on the street and see outdoor advertising like everybody else.
I believe that you can’t shelter children from a commercial world – we have chosen a commercial world and to live in capitalist society, so that’s where we stand. But what you can do is to try to make sure that in those areas which are specifically targeting children, you are only presenting ‘healthier for you’ products and helping parents to support their efforts to ensure healthy lifestyles.
Secondly, you need to be educating children to be critical in a world which is commercially filled.
Is the current EU legal framework responsible?
First of all, we all need rules to set an even playing field. Because the companies we are talking about are big companies that have been on the market for long time and have a very strong sense of CSR and they don’t want to be undermined by rogue traders – small companies that come to market, do things illegally, and try to mislead people to make fast money and then disappear from the market. This happens every day across all sectors.
It is in our interest is to have a strong legal framework which European citizens trust.
The important thing with the current legal framework is that it understands and recognises the role that advertising self-regulation plays. And when we talk about self-regulation it is not about the industry regulating itself, but advertising standards authorities. It gives a place for the industry to go above and beyond the law.
The advertising industry has long understood that in today’s environment it is better to be policing yourself – to have a body called the Advertising Standards Authority to which consumers or competing companies can make a complaint, which is very quickly resolved within the industry.
And the current EU legal framework understands and recognises this principle – that industry self-regulation is fundamental. Even EU consumer organisations all realise that there is a need for a self- regulatory body.
In 2006 we had these discussions with EU regulators, consumer and public health groups who said that ideologically, self-regulation does not work. And we said, OK - imagine a world without self-regulation. A consumer would not be able to make a complaint about an ad, but would have to start legal proceedings against the company, which would be costly and time-consuming. By the time the issue were resolved, the perceived damage would be done. The only people who would profit would be lawyers.
Advertising self-regulation provides effective, quick and free consumer redress. It also proactively polices all forms of marketing communications to make sure that they are legal, decent, honest and truthful.
How about at scientific level – regarding health and nutrition claims, for example? Some 80% of the claims filed for approval within the European Food Safety Authority (EFSA) have already been rejected – this does not sound very responsible to me. Can we say the claims case is an industry failure regarding responsible marketing?
I’m not an expert here. But I’m aware that this is a major issue and you need to ask the food industry about it, because I can only talk about when that claim is advertised, so as such it is not an advertising industry issue.
But I’m aware that it has created a lot of discussion and this is clearly an area where regulation is required – because as you said, a lot of claims that were made previously cannot be made now on the base of EFSA rulings. And that is good for consumers, there is no doubt about that – health and nutrition claims need to be scientifically substantiated.
But I would not so much say that it is a failure on the part of industry as it is a success in terms of the regulator – for being able to sit through those claims and make scientific substantiation relevant to EU citizens.
One industry representative recently told me that the interests of big multinationals are no longer only in the economy, and they wish to do more societal engagement, whether regarding education, nutrition, health, etc. Is this something that is discussed more generally in the advertising industry?
Companies like Coca-Cola understand that they have two things of value: they have their tangible assets – the bottles that have not yet been sold, their supply chain, offices, etc., and if these were sold tomorrow they would get a price for them.
The second thing is probably more important, and that is the intangible value of Coca-Cola – the brand.
Estimates show that – depending on the company and the sector – anything between 30% and 75% of the value of a brand is intangible – in how many millions of minds does the brand resonate, and that is key in a globalised market. And leading companies understand the importance of building that intangible brand value.
If we compare a company to a person, it is not so much the skills of that person, but how much you like that person or how much does that person make you feel good and how nice that person is. And if companies see their brands as ‘corporate people’, they understand that they are much more valuable being friendly and doing the right thing.
In a society where consumers ask for more and are empowered to ask for more through social media and new technologies, the requirement for social responsibility is greater than ever. And in this new world paradigm, it is important to do and be seen to do the right thing. And for big brands like Coca-Cola it is extremely important, because they understand the importance to their brand value of all these intangible components.
So, yes, being the right brand, a nice guy and doing the right thing is important for today’s leading brands.
Could brand value be used to do something more than just selling a product, such as associating a brand to a healthy lifestyle, for example?
Many of the big leading brands are enlightened companies who understand that they need to give consumers more than just a good product experience. As a parent you don’t want to feel that your purchase decisions are being undermined by companies appealing directly to their child behind your back. So the fact that several major companies have pledged not to advertise directly to children can help parents feel empowered to make the final choice and perhaps also helps parents make healthier decisions.
I believe that many companies are trying to align themselves with the societal push for a healthier society.
You can see the same with the energy sector, for example – they are trying to align with society’s push for a more environmentally-conscious and sustainable society. In the automotive sector, companies are trying to make their cars more efficient, and so on.
Industry loves to talk about consumer education and consumer empowerment. What role do you see for industry in consumer education?
If we come back to your question on whether it is ethical to be advertising to children at all…I asked whether it is possible to hide advertising from children.
While I think it is impossible to hide all advertising from children, it does not stop you from thinking about it and trying to do what you can to help give children the skills to be critical and discerning in a commercially-filled world.
According to academic and scientific research, children under six years old can’t understand the difference between advertising and editorial. But we are not going to hide advertising from them.
The research also indicates that six to eleven is the formative period during which children start to develop the skills necessary to be critical when faced with commercial communications. But as far as we were aware, back in 2002 there was nothing in schools which taught children to be media-literate or at least media-educated.
So we launched Media Smart (www.mediasmart.org.uk). The advertising industry paid for it and gave the money directly to academics and experts in the field who developed the materials free of charge. These materials were offered to teachers in order to teach children how to be critical in a media-filled world.
Since 2002, the materials have been used to teach three million children across the EU how to be critical when faced with commercial communications. It was started in the UK and has since been rolled out in several EU countries – Belgium, the Netherlands, Germany, Finland, Sweden, Portugal, Hungary and now in France.
While NGOs are often upset saying ‘industry is going into schools, teaching’ – it is simply not true. Industry pays for it and independent academics – such as Professor David Buckingham in the UK – develop the materials.
Now the pack has become ‘Digital Adwise’ – teaching children things to bear in mind, when they go online, how to be critical.
So, industry does not claim to have a role in educating children, absolutely not, but in enabling it.
98% of the teachers who used the materials said they were good or excellent and that they would use them the next year as well. So the material provided helps teachers hugely, because they’re given materials to teach something that is extremely relevant and where there is a clear consumer need.
Materials were originally non-branded, but the first thing the teachers said was ‘please give us the materials next year branded because otherwise it does not reflect real life’. So some markets actually want the materials branded. Some don’t.
Now there is some interest from Australia and the US to try to roll out the same programme. The programme is continuously being cited everywhere – even in the Juvin report - as a best practice example. It is enlightened self-interest by the industry.
Whether you think it is legitimate to advertise to children or not, children are going to see advertising. So I think it is enlightened from the companies to be funding this kind of programme – bearing in mind that in the real world you are not going to be able to stop any form of marketing communications when children are concerned. It is unfeasible.
So any company who has products that may be attractive to children should be looking at this kind of programme, because they have a vested interest in making sure that children are smart when seeing commercial communications.
Responsible marketing always seems to only be about children. What about adults?
We don’t want to live in a nanny state – companies have a legitimate right to be operating and part of their operations is to innovate and bring new products to the market. And how do they bring them to the market? They market them: that’s how capitalism works.
Grown-ups are grown-ups and they should not be wrapped up in cotton wool. They should have the faculties to fend for themselves. But when it comes to children, that’s a more sensitive issue.
Do you have any special message on food and responsible marketing?
Yes, about the role of advertising and marketing promotions in relation to the broader debate on obesity.
Obesity and being overweight is pretty complex. There are a lot of things that lead to them. Of course advertising has an impact on food choices and preferences, otherwise companies would not do it. But as one part of the totality of different factors, all research shows that it is a very small part. One study estimates the impact of food advertising on food choice at just 2%. But there has been a disproportionate focus on marketing and advertising because it is an ‘easy fix’.
Changing the whole world, which in many countries has moved from manufacturing to a service-based economy, where we all sit in front of computers and kids don’t go out and play sports as they used to – these are hard things to solve, while marketing is an easy thing.
Having said that, it is not for the marketing industry to say ‘we don’t do anything’.
This is why companies realise they need to be advertising responsibly – to change what you advertise and how you advertise it. The now 16 companies representing 75% of food marketing in the EU have reduced all their TV advertising, of all products, by over 30% since 2005. In addition, children’s exposure to products that do not qualify as ‘better for you’ has been reduced by 60%.
All this has been done through self-regulation, as companies have understood that there is political and public concern around food marketing.
But to fix obesity and being overweight will take a bird’s eye view of all the contributing factors. And it will not just be a disproportionate focus on marketing and advertising, which is probably being unfairly portrayed as the ‘bad guy’ in all of this debate.
The problem is that it remains an easy fix for politicians operating in a limited time frame. Perceptions are everything in politics and politicians are under pressure to seek to do things that are quick fixes. But as any health expert will tell you: nobody can fix obesity and overweight in a four-year term. It needs joined-up, cross-sectoral policymaking over a sustained period of time where things like education, smart urban planning, investments in health care and in promoting physical activity in schools and so on are fundaments of any government policy.
People need to see the bigger picture. But sometimes regulators, activists and the media are quick to find a scapegoat. There is nothing more tragic than childhood obesity and that creates hysteria in the press, and it is very difficult as an industry to find a middle ground and be reasonable in an emotive debate. It is easy to be emotional about this, it is difficult to be pragmatic and see the big picture and how all different issues interplay and then make a sensible and proportionate policy based on everything.
But as I said there will always be an inclination to restrict marketing, because it is the most visible of any company’s activities.