Responsible marketplace activity
Given that our core purpose is bringing more sociability and wellbeing to our world, it goes without saying that misuse of our products not only undermines this purpose but is fundamentally at odds with our reason for being. We want our products to be consumed responsibly, both because it is right and because it will ensure the future sustainability of our business.
One of the ways we can encourage the responsible consumption of our products is through our marketing. Our portfolio includes some of Australia and New Zealand's most iconic brands, and we believe these strong brands can play a positive role in helping consumers make educated choices about the food and beverages they consume.
Our commitment to sociability and wellbeing permeates our entire marketing spectrum – from research, product design, marketing communications and sales, right through to point of purchase.
Consistent with our value of 'acting with integrity' we seek to achieve best practice in self-regulation, supporting a thorough system of marketing and communications controls. In Australia and New Zealand we are signatories to a number of industry co-regulatory and self-regulatory codes governing advertising and promotional standards. We believe self-regulation is better than legislation, as it allows the rules to evolve with the landscape and reflect the realities of our individual business units.
To ensure a consistent approach to self-regulation across our newly combined business, in 2010 we developed the Lion Nathan National Foods Code for Responsible Marketplace Activity which is rolled out internally for our marketers, as well as to our external agencies.
The code sets out our commitment to ensure our practices don't contribute – in any way – to the problems of alcohol misuse, obesity or excessive consumption in general. It's an extension of the pre-existing Lion Nathan Code, combined with broader National Foods industry commitments, such as our role in the Australian Food and Grocery Council's (AFGC) Responsible Children's Marketing initiative. National Foods became a signatory to this initiative in February last year.
Australia
In Australia, both our Lion Nathan and National Foods businesses are signatory to codes designed to ensure all ads are legal, decent, honest and truthful, have been prepared with a sense of obligation to the consumer and society, and are fair in their references to competitors. These include:
- The Australian Association of National Advertisers (AANA) Code of Ethics
- The AANA Food and Beverages Advertising and Marketing Communications Code
- The AANA Environmental Claims in Advertising and Marketing Code
- The Free TV Commercial Television Industry (CTI) Code of Practice
- The ASTRA Codes of Practice for Subscription TV
- The Commercial Radio Codes of Practice
- The Australian Packaging Covenant
Furthermore, our agency marketing partners are bound by the terms of the Advertising Federation of Australia (AFA) Agency Code of Ethics.
The Advertising Standards Board administers complaints about language, discrimination, taste and decency, portrayal of violence, sex, sexuality and nudity, and health and safety.
National Foods, which provides a wide range of products for children and adults, adheres to a number of codes specific to its business operations:
- The AANA Code for Advertising and Marketing Communications to Children
- The Australian Food and Grocery Council's Responsible Children's Marketing Initiative
- The National Food Authority Code of Practice on Nutrient Claims in Food Labels and in Advertisements
- The Australian Food and Grocery Council's Code of Practice for Food Labelling and Promotion
These codes ensure our products and their individual nutritional profiles are marketed accurately and in line with community expectations.
In 2010 the Advertising Standards Bureau reviewed one National Foods and nine Lion Nathan advertisements. All complaints against Lion Nathan advertisements were dismissed. However the one National Foods complaint was upheld on the grounds that it was in breach of section 2.2 of the AANA Food and Beverages Advertising and Marketing Communications Code. The advertisement was subsequently modified.
In addition to the codes listed earlier, we adhere to the Alcohol Beverages Advertising Code (ABAC), which is specific to alcoholic beverages in Australia.
The ABAC is a co-regulatory system for alcohol advertising. Guidelines have been negotiated with government, consumer complaints are handled independently and all costs are borne by industry. A management committee comprising industry, advertising and government representatives administers the code. As with the AANA Code of Ethics, complaints are received via the Advertising Standards Bureau and can be made confidentially. An independent panel led by the former Federal Attorney General Michael Lavarch adjudicates them.
A further safeguard to which we subscribe is the Alcohol Advertising Pre-Vetting Scheme (AAPS), whereby community representatives pre-screen our marketing materials before they're launched. The scheme works well. In any given year around 10% of proposed advertisements across the total industry are rejected outright at the pre-vetting stage, preventing them from ever being broadcast or printed. Around a further 5% of proposed advertisements are only approved after modification.
In 2010, the ABAC Panel reviewed six Lion Nathan advertisements. All complaints against these advertisements were dismissed.
In addition to the ABAC, there are specific requirements for alcoholic beverages addressed in some of the codes listed earlier. These include:
- CTI Code of Practice – Section Six sets out placement restrictions on certain types of television advertisements that are recognised as sensitive. Alcohol is included within that section.
- Commercial Radio Codes of Practice – all radio advertising for alcohol is subject to review via this code, which is monitored by the Federation of Australian Radio Broadcasters (FARB).
To further educate our people and the agencies we work with, a new toolkit was developed for Lion Nathan Australia in 2010. The toolkit and its accompanying intranet site serve as a one-stop-shop for legal advice, covering all of the legislation, industry and internal codes that govern the way we market our brands. Training is being rolled out across all business units and external agencies in the coming year.
New Zealand
In New Zealand, Lion Nathan adheres to all relevant local codes, including:
- The Advertising Standards Authority (ASA) Advertising Codes of Practice
- The ASA Code for the Naming, Labelling, Packaging and Promotion of Liquor
- The New Zealand Packaging Accord (since replaced by the Accredited Voluntary Product Stewardship Programs)
- The Food Standards Code
In addition to the these codes, we subscribe to the Liquor Advertising Pre-vetting System (LAPS) and the Liquor Promotion Pre-vetting System (LPPS) administered by the Association of New Zealand Advertisers, whereby internal delegated authorities are trained to approve all sales and marketing materials and activity prior to being released into the market. This ensures compliance with all government self-regulatory codes and our own commitment to responsible marketplace activity.
The Advertising Standards Authority self-regulates advertising in New Zealand. An independent board hears complaints and there is a right of appeal to the independent appeal board. In the event of a complaint being upheld, the advertiser, agency and media are asked to withdraw the advertisement. There has been 100% compliance by industry with this request so far. All decisions are released to the public via the media and are widely reported.
In 2010, the ASA Complaints Board reviewed 10 Lion Nathan advertisements. All complaints against these advertisements were dismissed.