Summary of presentation by
The Institute of Advertising Practitioners of Ireland (IAPI)
To
THE JOINT COMMITTEE ON HEALTH AND CHILDREN –
November 17, 2011
INTRODUCTION – IAN YOUNG
Good Morning. I would like to introduce my colleague, Patrick Hickey and my
name is Ian Young.
We are presenting on behalf of The Institute of Advertising Practitioners of
Ireland (IAPI). IAPI represents over 60 agencies employing over 1500 people.
Irish agencies have built up a reputation for quality of production and creative
output, and ads are produced here for other markets.
I am Managing Director of Irish International Advertising, and Diageo is one of
our clients. Patrick Hickey is Managing Director of Rothco Advertising, and
Heineken is one of their clients.
This is a complex issue. There is no silver bullet nor one single villain. The other
key factors impacting on this area include retail pricing and controls, parenting,
peer pressure, social and cultural influences and access.
CURRENT PROCESS AND RESTRICTIONS –
We acknowledge and concur with the comments of An Taoiseach on November
7th – “Nobody wants to take away the rights of people to enjoy themselves but
there has to be an understanding that excess does serious damage and the longterm impact and consequences of excess alcohol (and use of drugs) leads to
enormous health challenges”
We do not intend to repeat the content of the ASAI or AMCMB presentations.
Their contribution outlined the various codes, restrictions and complaints
process, which currently exists and with which we all comply.
What we hope to achieve is to paint a picture of how the current codes are
implemented and adhered to in both the letter and spirit within across all
elements of an agency working with an alcohol client.
Let us talk briefly through the process
We are talking about advertising – paid for communications – across a range of
media
We are currently working under a number of different – yet supporting - codes.
These are from the ASAI, the Broadcasting Authority, as a regulator and the
Central Copy Clearance Ireland (CCCI).
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Oversight and reporting is undertaken by the Alcohol, Marketing
Communications Monitoring Body, an independent entity, which monitors
compliance to the code and reports directly to the Minister for Health.
I am going to talk about the separate scrutiny and restrictions around both
content and placement
For content, each individual piece of advertising is pre-vetted – this can be copy,
images or concepts. The vetting takes place at all stages of production and is
undertaken by two managers. Pre-vetting is undertaken for all advertising
designed for the Irish market place. Retailers are exempt from these restrictions
– we have our concerns on this, which we will outline during our presentation
Between the client and agency, there is extensive engagement to ensure that the
codes are adhered to at all stages. Both Brand Managers and supporting
marketing staff and agency teams undergo rigorous training on the codes and
their implementation
No cast member can be – or look as if they are – under 25. There can be no
implied social or sexual success and there can be no signs of group drinking
When the advertisement is complete, it must be submitted to the CCCI for final
approval – this can take a number of weeks. At this stage, a final approval
clearance number is issued.
Its important to note that prior acceptance by the CCCI is merely an indication
that the completed advertisement is likely to comply with the codes. As there
may be significant differences between a script, the early development stages of
an advertisement and the finished production, final approval is essential
The CCCI scrutiny covers alcohol brand advertising for TV/cinema, radio,
press/magazines, outdoor/transport, internet/digital and any other nontraditional media such as ambient
When content is approved, the agency must then ensure that the placement of
the ad is also in accordance with the codes, which were agreed between the
Department of Health, brand owners and others involved in alcohol advertising.
This covenant was formed in 2002 and the codes strengthened in 2008.
I am now going to hand you over to my colleague – and competitor - Patrick
Hickey – who will talk through the market dimension
Patrick Hickey
All of our clients operate in a commercial environment. In an open economy,
companies operate on the principle that they communicate to their public to
provide information to them within the dynamic of a purchasing decision.
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Obviously, this must be done within specific and acceptable guidelines, from a
societal perspective
The brief we receive from a client is entirely related to the brand.
There is absolutely no consideration nor brief to increase or drive consumption
levels, unit levels or to encourage excess consumption.
The Key Performance Indicators, which our clients impose on us are around how
a brand is perceived – is it trusted, are the core values understood.
It is true to say that Ireland has a social, financial, Health and cultural problem
with the misuse and over consumption of alcohol through our society.
What role does paid for advertising play in this? We accept that well funded,
well-produced advertising is designed to be noticed
The brands that spend money on adverting are the ones who in the main support
every code both in spirit and letter.
Curtailing advertising will have an effect. It will ensure that the more responsible
brands market share will decline over time.
However their loss will result in gain for another cohort.
The cheap vodka, cheap beer etc will simply grow in share. Most of these brands
operate independently outside the code.
You will never have seen an ad for a jagger bomb or a fat frog. Both of which are
consumed in large quantities every weekend all over this country.
We have always complied fully with any legislation or code that we have been
asked to as an industry.
We would like to support the call for below cost selling. We would also
recommend an extension to the codes reach to include every activity that an
alcohol brands are involved in. We would like to recommend that both agency
and client receive punitive fines if they are found to be in breach of such codes.
We are not trying to defend the indefensible, however in the interest of balance
we must agree that of all the actions that may be recommended by the
committee curtailing the communication of the compliant brands is the easiest
but may not deliver the effect that is hoped for.
The current codes, which we work to, have the potential to be extended to
encompass other communications and integrated marketing and
communications. This reach could involve greater integration with retailers and
the on and off trade.
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Thereafter, the advertising sector would welcome an opportunity to work with
the statutory agencies and regulators in any initiative, which would strengthen
the reach and implementation of the codes
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