2011
Monitoring Report
November 2011
2
Executive summary & key results
Report by Lucien Bouis, independent reviewer
About the EU Pledge
Compliance monitoring: Advertising
TV
Internet
Beyond compliance: Measuring change in the balance
of advertising
Compliance monitoring: Primary Schools
Next steps
Annex 1 – Accenture Compliance Report
Annex 2 – BDRC Compliance Report
Table
of
contents
3
6
9
12
15
17
19
20
34
3
Executive summary & Key results
Background
The EU Pledge is a voluntary initiative launched by leading food and beverage companies to change food and beverage advertising on TV, print and internet to children under the age of twelve in the European Union.
Signatories commit to changing the way they advertise to children under 12 years old by respecting the following two criteria:
No advertising of products to children under 12 years, except for products which fulfil specific nutrition criteria based on accepted scientific evidence and/or applicable national and international dietary guidelines1.
No communication related to products in primary schools, except where specifically requested by, or agreed with, the school administration for educational purposes.
This third monitoring exercise was carried out in the first half of 2011 by the following independent third parties:
Accenture Media Management2, to review EU Pledge member companies’ compliance with the commitment relating to food and beverage advertising on TV, print and internet; and
BDRC Continental3, to monitor compliance with the commitment on product-related communications in primary schools.
The methodology and processes of both monitoring exercises have been independently reviewed by Mr. Lucien Bouis, former member of the European Economic and Social Committee and former Director of the Bureau de Verification de la Publicité (BVP, now called ARPP, Autorité de Régulation Professionnelle de la Publicité – the French advertising Self-Regulatory Organisation).
Key 2011 results
Three years into the EU Pledge, the record of compliance is again very positive and consistent with previous years:
TV: The overall compliance rate is 99.1%
Print: The overall compliance rate is 100%
Online: The overall compliance rate is virtually 100%
Primary schools: The overall compliance rate is 98%
1
To date there is no one single global or European set of nutritional guidelines, because of the substantial differences across food cultures. There are nonetheless national and some elements of international guidance (e.g. World Health Organisation). Such guidelines usually include recommendations on daily caloric/nutritional intake and dietary habits/regimens and are dietary guidelines, not specific to individual foods. EU Pledge companies have developed their own nutritional guidelines on the basis of the most widely accepted national and international guidelines that exist (e.g. WHO, FAO, USDA, IOM, EURODIET). They have done so individually to reflect the diversity of members’ product portfolios. Some include products from a number of categories; others include only one category (e.g. confectionery, soft drinks). Other EU Pledge member companies still have taken the decision not to advertise any of their products to children under 12. All applicable nutritional guidelines are published as part of the individual company commitments under the EU Pledge on www.eu-pledge.eu
2 Accenture is a global management consulting, technology services and outsourcing company. Accenture Media Management helps co mpanies
measure and optimise investments in marketing, media, retail and digital.
3
4 In addition to monitoring the implementation of commitments, EU Pledge member companies have sought to measure the change in the overall balance4 of their food and beverage advertising to children as a result of the EU Pledge and of companies’ individual commitments.
For the third year running, monitoring confirms a downward trend in children’s exposure to TV food advertising by EU Pledge member companies. Monitoring by Accenture, PWC and BDRC Continental since 2009 has covered in total 12 EU markets for advertising and 12 EU markets for in-school communications (c.81% of EU population in total).
Key results:
A very substantial reduction in children’s exposure to advertising for products that do not fulfil better-for-you criteria through children’s programmes (>50% <12 audiences): -79% this year. Over all markets monitored in the past 3 years the average is -85%
A reduction in children’s exposure to advertising for products that do not fulfil companies’ better-for-you criteria in all programmes: -29% this year. Over all markets monitored in the past 3 years the average is -48%.
An overall reduction in children’s exposure to advertising for all EU Pledge member companies’ products (regardless of nutritional criteria): -21% this year. Over all markets monitored in the past 3 years the average is -29%.
Enhanced 2012 commitments
The EU Pledge is a dynamic initiative. While it provides a common framework, member companies can make commitments that go beyond it, and several do. Since its launch, over half of the founding member companies have stepped up their corporate commitments, tightening the way they define advertising to children, broadening the scope of their actions and strengthening the nutritional criteria they use to classify better-for-you options.
In the same spirit and following constructive dialogue with stakeholders, the EU Pledge has decided to enhance its framework voluntary commitments. The enhanced commitments will apply to all existing and any new members of the initiative throughout the EU.
The objectives of the enhanced commitments are twofold:
To raise the bar in terms of how advertising to children is defined: Currently, EU Pledge member companies do not advertise products to children under 12 years, except for products which fulfill specific nutrition criteria based on accepted scientific evidence and/or applicable national and international dietary guidelines. For the purpose of the initiative, “advertising to children under 12 years” means advertising to media audiences with a minimum of 50% of children under 12 years. EU Pledge member companies commit to lowering the audience threshold to 35% of children under 12 years. This tougher threshold will have the effect of covering more media channels that have a significant child audience.
To improve the coverage of the commitment in the online sphere: Currently, the EU Pledge commitment applies to advertising on TV, print media and third-party internet advertising. EU Pledge member companies commit to applying the commitment also to company-owned
4
5 websites. By extending the coverage of the commitment to cover both third-party online advertising and brand websites, the EU Pledge will cover online marketing comprehensively.
New enhanced Pledge commitments:
No advertising of products to children under 12 years, except for products which fulfil specific nutrition criteria based on accepted scientific evidence and/or applicable national and international dietary guidelines. For the purpose of this initiative, “advertising to children under 12 years” means advertising to media audiences with a minimum of 35% of children under 12 years. This rule will be applicable as of 1 January 2012 throughout the EU.5
In the online sphere, the above commitment will apply to marketing communications for food and beverage products on company-owned websites, in addition to third-party internet advertising. Member companies will develop and follow detailed guidance to apply this commitment by 1 January 20126.
No communication related to products in primary schools, except where specifically requested by, or agreed with, the school administration for educational purposes.
The EU Pledge will commission independent, third party annual compliance monitoring of the EU Pledge commitment for company-owned websites to complement existing monitoring of third party websites.
Growth in membership
The EU Pledge was launched in December 2007 by eleven leading food and beverage companies, representing approximately two-thirds of food and non-alcoholic beverage advertising spend in the European Union.
The initiative gained 6 new members in 2010, as the European Snacks Association (ESA) joined as an associate member, with six of its leading corporate members signing up to the EU Pledge commitments: Estrella-Maarud, Intersnack, Lorenz Snack-World, Procter & Gamble, Unichips - San Carlo and Zweifel Pomy-Chip. A further ESA member company, the Chips Group, joined in 2011.
Two additional leading companies have joined the initiative as a result of their acquisition by existing EU Pledge member companies: Wrigley through its acquisition by Mars Inc. in 2009; and Cadbury through its acquisition by Kraft Foods in 2010.
In November 2011 McDonald’s joined the EU Pledge, bringing membership to 19 companies, representing over 80% of EU food and beverage advertising spend in the EU.
5
In order to allow for adjustment of media buying practices and licensing agreements, individual companies will be granted a transition period not exceeding one year, i.e. until 1 January 2013 at the latest, provided this is stated clearly in their individual corporat e commitment published on the EU Pledge website.
6
6
Report by Lucien Bouis, independent reviewer
Objectives
In the context of the EU Platform for Action on Diet, Physical Activity and Health set up by the European Commission’s Directorate General for Health and Consumers, and with the support of the World Federation of Advertisers (WFA), 18 major food and beverage companies have made a commitment affecting the way they advertise to children under 12, called the “EU Pledge”.
Two reviews of the EU Pledge were conducted in 2009 and 2010 and were presented to EU Platform Members and to the European Commission. Those reviews found the methodology and results of the monitoring satisfactory.
EU Pledge members have decided to undertake a similar monitoring exercise during the first three months of 2011 with the same criteria but in different EU Member States. New members have also joined the programme.
At the request of Landmark Europe, I agreed to act as independent reviewer for this third monitoring exercise. The objective was to assess whether the compliance monitoring, performed by two independent agencies (Accenture Media Management and BDRC Continental) was carried out with an appropriate methodology, resources and diligence.
The commitment of the EU Pledge is twofold:
No advertising of food and beverage products to children under the age of twelve years old on TV, print and internet, except for products which fulfil specific nutrition criteria based on accepted scientific evidence and/or applicable national and international dietary guidelines. No product-related communications for food and drinks in primary schools unless requested by
or agreed with the school administration for educational purposes.
Communication in primary schools
Concerning the compliance of the EU Pledge commitment for communications in schools, adequate means were put in place in order to ensure the reliability of the results. The independent agency BDRC Continental picked a sample of schools in Germany, Ireland, Poland and Spain.
The monitoring took place between May and June 2011 during which over 2885 schools were contacted to be recruited for the survey. Those that accepted were surveyed electronically.
The answers of 400 schools, 100 per country – a sample determined by BDRC as statistically sufficient – were obtained and analysed. Schools were selected to reflect a suitable geographic and socio-economic balance in each country.
Consistently with the past two years, the questionnaire was submitted to senior school staff (headmasters, teachers) in order to assess children’s exposure to EU Pledge member companies’ commercial communications on or at:
7 - school property
- vending machines
- school furniture and equipment - school publications
- events organised at/by the school
- sponsoring requested by or agreed with the school administration.
Taking into account potential interpretation issues, BDRC drafted a series of definitions that have ensured reliable responses. It is worth noting that the non-compliance rate is below 2%.
It is interesting to point out that some open questions were asked this year in order to obtain more detailed answers from school staff on non-compliance cases. EU Pledge members have been able to take corrective actions quickly where necessary.
Furthermore, the results of the survey have allowed EU Pledge members to get in touch directly with schools that highlighted a case of non-compliance (if agreed by the school). Most respondents agreed to be contacted by the advertiser in breach of the EU Pledge commitment to discuss the case.
Advertising and Media
Between January and March 2011, Accenture Media Management monitored television, print and internet media of the countries selected. Accenture put in place sufficient resources to ensure that the compliance monitoring was rigorous and reliable. Appropriate techniques were used in order to identify channels, publications and websites, and to conduct TV audience analysis.
Television
For the television compliance monitoring exercise, all advertisements broadcast on all channels (except for satellite and cable channels when the data was not available) in the 7 sample countries (France, Ireland, The Netherlands, Poland, Portugal, Romania and Slovenia) were analysed to see whether any of them promoted EU Pledge members’ products at a time of broadcast when the audience was composed of more than 50% of children under 12 years.
During the compliance monitoring period, between January and March 2011, EU Pledge members broadcast 753,299 spots. Less than 1% of all ads broadcast by EU Pledge members were found in breach. Accenture compared these figures with similar data from 2005, before the EU Pledge was adopted, and concluded that the signatories have effectively reduced children’s exposure to the advertising of some of their products.
For compliance monitoring in print media, Accenture drew up a list of publications which were considered likely to attract a majority of readers under 12 years in five sample countries.
All advertisements published in these selected titles in the five countries (Ireland, the Netherlands, Poland, Portugal and Romania) during the first three months of 2011 were analysed to assess whether
8 any of them contained advertisements for certain products of EU Pledge members. In the 113 titles
selected, no advertisements were found to be in breach of the commitment taken.
Internet
The compliance monitoring on the internet was performed following a method similar to the print advertising monitoring. A list of websites deemed by Accenture to be of particular appeal to children under 12 was drawn up and a manual analysis of all commercials (banners, pop-ups…) on these websites was made by Accenture representatives in each sample country (France, Ireland, The Netherlands, Poland, Portugal and Romania).
Only two cases of non-compliance were found. Taking into account the global reach of the internet and the limited lifespan of messages broadcast online, the results show very little non-compliance.
Conclusions
Taking into account the number of countries in the sample, the populations covered, the significant number of companies that are part of the EU Pledge, the diversity of their brands and product portfolios, as well as the range of media analysed, the compliance monitoring performed by Accenture and BDRC can be considered as faithful and reliable.
I have been fully informed of all the steps taken through the entire process and after having consulted the final reports, I can vouch for the seriousness and reliability of the results. They correspond to the terms of reference agreed to by all operators involved, BDRC and Accenture.
During the course of my mission, I want to point out that I have had full access to all information and all my questions were answered by Landmark Europe and the other agencies with whom I have been in regular contact and whom I have interviewed to assess the quality of their reports.
In view of the significant number of food and drink companies involved, and in light of their willingness to submit their commitments to independent verification, the results of this EU-wide self-regulatory initiative should be of great interest to all stakeholders involved in health and consumer protection. Finally, it is worth noting that other advertisers in the food and beverage sector have expressed their interest in joining the EU Pledge, and that this programme has been and is being replicated in several countries across the world.
Brussels, 15 September 2011 Lucien Bouis
9
About the EU Pledge
The EU Pledge is a voluntary initiative by leading food and beverage companies to change food and beverage advertising to children under the age of twelve on TV, print and internet in the European Union. The EU Pledge was launched in December 2007 as part of signatories’ commitment to the European Union Platform for Action on Diet, Physical Activity and Health, the multi-stakeholder forum set up by former EU Health and Consumer Affairs Commissioner Markos Kyprianou in 2005 to encourage stakeholders to take initiatives aimed at promoting healthy lifestyles in Europe. In the context of the EU Platform, the EU Pledge commitment is owned by the World Federation of Advertisers (WFA), which also supports the programme.
EU Pledge members
The founding members of the EU Pledge are the following companies: Burger King, Coca-Cola, Danone, Ferrero, General Mills, Kellogg, Kraft Foods, Mars, Nestlé, PepsiCo and Unilever.
The initiative gained 6 new members in 2010, as the European Snacks Association (ESA) joined as an associate member, with six of its leading corporate members signing up to the EU Pledge commitments: Estrella-Maarud, Intersnack, Lorenz Snack-World, Procter & Gamble, Unichips - San Carlo and Zweifel Pomy-Chip. A further ESA member company, the Chips Group, joined in 2011.
Two additional leading companies have joined the initiative as a result of their acquisition by existing EU Pledge member companies: Wrigley through its acquisition by Mars Inc. in 2009; and Cadbury-Schweppes through its acquisition by Kraft Foods in 2010.
In November 2011 McDonald’s joined the EU Pledge, bringing membership to 19 companies, representing over 80% of EU food and beverage advertising spend in the EU.
The initiative is open to any food and beverage company active in Europe and willing to subscribe to the EU Pledge commitments.
10
The EU Pledge commitments
The EU Pledge is a framework initiative whereby signatories are committed to changing the way they advertise to children under 12 years old by respecting the following two criteria:
No advertising of products to children under 12 years, except for products which fulfil
specific nutrition criteria based on accepted scientific evidence and/or applicable
national and international dietary guidelines
7. For the purpose of this initiative,
“advertising to children under 12 years” means advertising to media audiences with a
minimum of 50%
8of children under 12 years
9.
No communication related to products in primary schools, except where specifically
requested by, or agreed with, the school administration for educational purposes.
Participating companies must all meet these criteria, but can go further. The framework EU Pledge commitments provide a common benchmark against which companies can jointly monitor and verify implementation.Since the initiative was launched, all participating companies have made their individual corporate commitments within the framework of the EU Pledge programme. All founding member company commitments, published on the EU Pledge website (www.eu-pledge.eu), were implemented across the EU by 31 December 200810. Members that joined the EU Pledge in 2010 implemented their commitments
by the end of that year. Chips Group, which joined in April 2011, will implement the commitments by the end of the year.
To facilitate compliance with the EU Pledge commitments, member companies developed detailed implementation guidance, for all relevant staff in marketing, media planning and corporate affairs departments in all EU markets.
Third-Party Monitoring
In line with the Terms of Reference of the EU Platform for Action on Diet, Physical Activity and Health, EU Pledge signatories are required to monitor and report on the implementation of their commitments. EU Pledge member companies have committed to carry out independent, third-party compliance monitoring of the EU Pledge commitments.
7
To date there is no one single global or European set of nutritional guidelines, because of the substantial differences across food cultures. There are nonetheless national and some elements of international guidance (e.g. World Health Organisation). Such guidelines usually include recommendations on daily caloric/nutritional intake and dietary habits/regimens and are dietary guidelines, not specific to individual foods. EU Pledge companies have developed their own nutritional guidelines on the basis of the most widely accepted national and international guidelines that exist (e.g. WHO, FAO, USDA, IOM, EURODIET). They have done so individually to reflect the diversity of members’ product portfolios. Some include products from a number of categories; others include only one category (e.g. confectionery, soft drinks). Other EU Pledge member companies still have taken the decision not to advertise any of their products to children under 12. All applicable nutritional guidelines are published as part of the individual company commitments under the EU Pledge on www.eu-pledge.eu
8
This is a commonly agreed benchmark to identify media with an audience composed of a majority of children under 12 years old. This method of audience indexing has been agreed as a pragmatic system to determine the applicability of advertising rules. Nevertheless, this is a minimum common benchmark for all EU Pledge member companies. For further detail see: www.eu-pledge.eu
9
The rationale for this threshold is the strong degree of academic consensus that by the age of 12 children develop their behaviour as consumers, effectively recognise advertising and are able to adopt critical attitudes towards it. Although children between the ages of 6 and 12 are believed to generally understand the persuasive intent of advertising, care should be taken because they may not have a fully developed critical understanding. For further information see: http://www.wfanet.org/pdf/adv_papers/when_is_a_child_a_child.pdf
10
11 This is the third such monitoring exercise. The 2009 and 2010 Monitoring Reports are available on www.eu-pledge.eu. In 2011, EU Pledge member companies commissioned the following independent third parties to monitor implementation of the EU Pledge commitments:
Accenture Media Management11, to review EU Pledge member companies’ compliance with the commitment relating to food and beverage advertising on TV, print and internet; and
BDRC Continental12, to monitor compliance with the commitment on product-related communications in primary schools.
Both monitoring programmes were carried out during the first half of 2011; and both have been independently reviewed by Mr. Lucien Bouis, member of the European Economic and Social Committee and former Director of the Bureau de Verification de la Publicité (BVP, now called ARPP, Autorité de Régulation Professionnelle de la Publicité – the French advertising Self-Regulatory Organisation), whose appraisal of the fairness and accuracy of the monitoring methodologies and processes is given in this report.
11 Accenture is a global management consulting, technology services and outsourcing company. Accenture Media Management helps co mpanies
measure and optimise investments in marketing, media, retail and digital.
12
BDRC Continental is UK's largest independent full service market research agency.
12
Compliance monitoring: Advertising
Objective and Scope
Accenture Media Management was commissioned to carry out the independent monitoring of member companies’ compliance with the following EU Pledge commitment:
“No advertising of products to children under 12 years, except for products which fulfil specific nutrition criteria based on accepted scientific evidence and/or applicable national and international dietary guidelines. For the purpose of this initiative, “advertising to children under 12 years” means advertising to media audiences with a minimum of 50% of children under 12 years.”
For the purpose of this exercise, seven sample EU markets were chosen: France, Ireland, The Netherlands, Poland, Portugal, Romania and Slovenia. The intent has been to cover a number of new markets each year, within the limits of data availability and affordability, so as to assess performance in as broad a sample of Member States as possible. Some markets have been covered repeatedly (e.g. Spain in 2009 and 2010; Poland in all three years) in order to provide a benchmark.
TV
Methodology
Accenture Media Management was commissioned to analyse national audience data in the sample markets over a full three-month period. This data is provided by official national TV audience measurement agencies. Viewing estimates are obtained from panels of television-owning private homes representing the viewing behaviour of households.
The data provides detailed statistics about advertising spots: advertiser, product, channel, programme, date and time of broadcast, estimated audience and demographic breakdown – typically including the segment 4-12 years of age. In Portugal and Slovenia the only available demographic segment is children aged 4-14. The implication is a likely overstatement of non-compliance in these markets with respect to the EU Pledge commitment.
On this basis, Accenture gathered and reviewed all advertising spots for products marketed by EU Pledge member companies, aired in the seven markets during the period 1 January to 31 March 2011 - 753,299 spots were reviewed.
Spots for products that do not meet EU Pledge companies’ nutritional criteria, where applicable, were identified, on the basis of full product lists submitted by each member company for each market. For those member companies that do not apply nutritional criteria and do not advertise any products to children under twelve, all spots were included.
For all these spots, audience composition at the time of broadcast was analysed on the basis of national ratings data. This allowed Accenture to isolate ads aired at a time when the majority of the audience was composed of children under twelve years of age.
13 All spots for products that EU Pledge member companies have committed not to advertise to children under twelve, aired at times when the audience was composed of a majority of children under twelve, were deemed non-compliant with the EU Pledge.
Results
The overall weighted compliance rate was as follows:
99.1% of signatories’ TV advertising spots were compliant with the EU Pledge
commitment.
The detailed compliance rates reported by Accenture per market and per medium can be found in the Accenture presentation included in this report.
These compliance figures are comparable to those reported last year in different markets (2010 compliance rate: 98.87%).
Statistical anomalies and overstatement of non-compliance
It is worth noting that of the 4,272spots found technically non-compliant (i.e. achieving an under-twelve audience share above 50%, regardless of the time of broadcast and of the adjacent programme), only 19 can be considered to be certainly in breach of the spirit of the EU Pledge commitment, i.e. broadcast in or around children’s programmes as such.
The other 4253 spots included as non-compliant in this report are spots broadcast in or around general/adult programmes that were reported in national ratings data as displaying a share of children under 12 above 50%.
The reason for this discrepancy is that audience statistics for programmes and advertising spots with a small audience – included in these monitoring results – are not reliable: a small audience means a small sample of households, rendering the demographic analysis of the audience unreliable. For statistical reliability, marketers typically exclude advertising spots below 1 Gross Rating Point (GRP). GRPs are the measure of television ratings. They are calculated in relation to the target audience – children under 12 for the purposes of this analysis. In this case a spot with less than 1 GRP is a spot that reaches less than 1% of the under-12 audience in the country in question. These spots often display an implausible share of under-12 viewers: e.g. a spot during a sports programme broadcast at 2AM shows a child audience of 100%. This is the result of statistical anomalies.
Accenture’s analysis shows that if spots below 1 GRP (unreliable audience data) and night-time spots (clearly not targeted at children) are excluded, only 19 spots by EU Pledge member companies are non-compliant, as opposed to 4,272 if all spots are counted. All these cases were nonetheless included in the reported non-compliance rates for the sake of transparency and simplicity, even though they are, at worst, examples of “technical” non-compliance.
14 All instances of non-compliance were reported to the EU Pledge member companies concerned. Companies were thus able to identify each non-compliant spot by market, product, channel and time. This has allowed companies to take corrective action where necessary, to adapt media planning where appropriate, and to update guidance to marketing departments where needed.
Methodology
The methodology used for print differs from TV, because precise age-specific readership data for children’s press is not always available. Accenture therefore drew up a list of children’s titles in each market monitored, on the basis of national genre classifications used in the industry. The lists of titles selected for the compliance monitoring exercise per country are available in Annex I. The print monitoring exercise covered five markets: Ireland, The Netherlands, Poland, Portugal, Romania.
Using advertising data from national monitoring agencies (databases of all ads placed in the selected print titles), Accenture identified any advertising in these children’s print titles for products that EU Pledge members have committed not to advertise.
Results
No non-compliant ads were found, which means that
100% of signatories’ print advertising was
compliant with the EU Pledge commitment.
Internet
Methodology
Because there is no reliable demographic audience data for most websites, Accenture drew up a sample list of child-targeted websites in each market (France, Ireland, the Netherlands, Poland, Portugal and Romania). The lists of websites selected for the compliance monitoring per country are available in Annex 1.
Manual compliance checks were performed during a three-week period (during the second quarter of 2011) on the selected websites to assess whether EU Pledge members promoted products that did not meet companies’ nutritional criteria on these websites.
Results
The monitoring revealed two instances of non-compliance: two banner ads for products not meeting nutritional criteria on children’s websites – one in France and one in Romania.
Almost 100% of signatories’ online advertising was therefore compliant with the EU Pledge
commitment.
15
Beyond compliance:
Measuring Change in the Balance of Advertising
Objective and scope
In an effort to go beyond the assessment of compliance with their commitments, EU Pledge member companies have sought to measure the change in the balance of food and beverage products advertised to children under twelve, in order to assess the impact of the initiative and corporate policies implemented in the framework and spirit of the initiative.
Due to the lack of historic data for print and Internet advertising, this exercise was limited to TV advertising – still by far the dominant medium in terms of food and beverage marketing spend.
The year 2005 was chosen as a benchmark, coinciding with the launch of the EU Platform for Action on Diet, Physical Activity and Health.
Methodology
The outcome indicator used to measure the change in the balance of food advertising to children was the number of times that children under 12 years old saw ads by EU Pledge member companies, for products that do not meet companies’ nutritional criteria and for all EU Pledge company products, in the period 1 January – 31 March 2005 vs. the same period in 2011. This was measured in “impacts”, which is the statistical number of times each spot is viewed by one person and hence the most accurate measure of “exposure”.
Accenture was asked to report the findings in terms of:
Change in programmes with an audience composed of a majority of children, the minimum common benchmark applied under the EU Pledge initiative.
Change in general programming, i.e. all programmes aired during the monitoring periods in the seven markets during Q1 2005 and Q1 2011.
This analysis was carried out by contrasting two comparable sets of data:
The advertising and ratings data already analysed to measure compliance in Q1 2011.
The equivalent data for Q1 2005, i.e. all advertising spots for products marketed by EU Pledge member companies in that period on the same channels.
Outcome
The results reported by Accenture show a marked decline in children’s exposure to ads for products that do not meet companies’ nutritional criteria since 2005. This trend is visible on the basis of both change measurement parameters chosen, namely:
A 79% reduction in programmes with an audience composed of a majority of children.
A 29% reduction overall, i.e. in all programmes on all channels at all times.
16 For all EU Pledge member companies’ advertising across all products, i.e. regardless of nutritional criteria, this represents, in the seven markets monitored:
A 21% reduction overall, i.e. in all programmes on all channels at all times.
Discussion
These results show a continuing downward trend in the exposure of children under 12 advertising by EU Pledge member companies, representing c. three-quarters of EU food and beverage advertising spend. The trend is less marked that that observed in 2009 and 2010. While the reasons for this cannot be established with certainty, some likely factors are the following:
Different markets were covered.
The 2011 monitoring covered a different set of companies: 17 companies representing c. three-quarters of the market as opposed to 11 companies representing c. two-thirds of the market. The monitoring measures the market at specific points in time, providing three-month snapshots.
Quarter 1, 2011 was characterised by a significant upswing in advertising activity compared to 2010.
In some of the new markets covered, e.g. Romania and Slovenia, both the media and advertising markets are growing significantly. The overall growth tempers the downward trend in children’s exposure.
Media fragmentation - growth in the number of channels and platform - has accelerated. This means that advertisers broadcast more spots on more channels, but these spots reach smaller audiences. The result of this is an exacerbation of the problem of statistical reliability (see Advertising Compliance Monitoring section above). A comparison of the analysis with unfiltered data (all spots) and filtered data (only daytime spots – 06h00-21h00 – and only spots with at least 1 GRP – see box p.13) is illustrated in Figure I:
Figure I – Change in children’s exposure 2005/2011 – Comparison all spots vs. daytime spots
>1 GRP
17
Compliance monitoring:
Communication in primary schools
Objective and scope
BDRC Continental was commissioned to carry out independent monitoring of member companies’ compliance with the following EU Pledge commitment:
“No communication related to products in primary schools, except where specifically requested by, or agreed with, the school administration for educational purposes.”
For the purposes of this verification, four sample EU markets were chosen, to complement the geographical sample chosen for the advertising monitoring component: Germany, Ireland, Poland and Spain. Schools were audited between 26 May and 16 June.
Methodology
BDRC Continental pulled from lists of all primary schools of each country a random sample of schools, representative of the population of schools in terms of their geographical distribution in each of the countries. Schools selected from the sample lists were recruited by telephone and asked to complete an online questionnaire. The email addresses of the appropriate school contacts were gathered during the recruitment phone calls to allow an email with the embedded questionnaire link and audit instructions to be sent.
400 online interviews were conducted for the audit – 100 in each of the participating countries, ensuring a minimum confidence level of 95% and a maximum margin of error of 5%.
Online interviews lasted approximately 10-15 minutes and were conducted in the local language. As an incentive, respondents received a €30 voucher or charity donation for participating.
Instances of non-compliance reported include all incidences of commercial communications in schools – both authorised and unauthorised. The only exception concerned the provision of branded or unbranded sponsored school materials, authorised by the school in question and deemed to have an educational purpose. In this respect, only unauthorised sponsorship is included in the non-compliance figures.
The interviews aimed to identify whether advertising for products of EU Pledge signatories was present in the following locations/instances:
School property
Vending machines (including branded vending machines) School infrastructure
In publications and products produced for or distributed by the school During events organised by the school on school grounds
Material from food and beverage companies (unless provided with the school’s agreement and with an educational purpose)
18 Responses were collected and analysed by BDRC Continental.
Results
The overall weighted compliance rate was 98%, with a breakdown per type of infringement provided in Figure II below:
Figure II – Compliance results 2009-2011 – per type of infringement (BDRC)
The results of the schools compliance monitoring exercise are set out in more detail in the BDRC report in Annex II.
The 2011 compliance results constitute a significant improvement over the 2009 and 2010 results. They are not strictly comparable, because the countries monitored are different. However, it is likely that the improved results are due at least in part to the refinement of the questionnaire used by BDRC Continental. This year’s survey included an additional question, asking respondents to describe in some detail the commercial communication found. This enabled BDRC to conduct a better qualitative assessment of the responses and isolate instances that were reported as non-compliance but were actually not (e.g. a branded diary brought in by a teacher or an advertisement at a venue outside school premises, visited on a school trip).
Follow-up
Each EU Pledge member company was informed of reported instances of non-compliance relating to their brands, per instance of breach and per market. School staff members interviewed were asked for the permission to be re-contacted by either BDRC Continental or EU Pledge member companies themselves. Permission was granted in more than half of cases, allowing companies to follow-up with schools on cases of non-compliance learn from these instances and adapt their practices and/or guidelines where appropriate.
19
Next steps
Launched in December 2007, the EU Pledge has been able to demonstrate a high level of member companies’ compliance with their commitments as well as a significant change in the balance of food advertising to children in the EU towards better-for-you options. The membership of the initiative has also grown from 11 to 19 member companies.
The EU Pledge is a dynamic initiative. While it provides a common framework, member companies can make commitments that go beyond it, and several do. Since its launch, over half of the founding member companies have stepped up their corporate commitments, tightening the way they define advertising to children, broadening the scope of their actions and strengthening the nutritional criteria they use to classify better-for-you options.
In the same spirit and following constructive dialogue with stakeholders, the EU Pledge has decided to enhance its framework voluntary commitments. The enhanced commitments will apply to all existing and any new members of the initiative throughout the EU.
The objectives of the enhanced commitments are twofold:
To raise the bar in terms of how advertising to children is defined: Currently, EU Pledge member companies do not advertise products to children under 12 years, except for products which fulfil specific nutrition criteria based on accepted scientific evidence and/or applicable national and international dietary guidelines. For the purpose of the initiative, “advertising to children under 12 years” means advertising to media audiences with a minimum of 50% of children under 12 years. EU Pledge member companies commit to lowering the audience threshold to 35% of children under 12 years13. This tougher threshold will have the effect of covering more media channels that have a significant, even though not majority child audience.
To improve the coverage of the commitment in the online sphere: Currently, the EU Pledge commitment applies to advertising on TV, print media and third-party internet advertising. As of 1 January 2012, EU Pledge member companies will apply the commitment also to company-owned websites. By extending the coverage of the commitment to cover both third-party online advertising and brand websites, the EU Pledge will cover online marketing comprehensively. The first priority for 2012 will be to implement these enhanced commitments and to develop a suitable methodology to monitor in particular the implementation of the new commitment relating to company-owned websites.
In parallel, the EU Pledge will continue seeking to broaden its membership, address remaining issues of non-compliance, continue work on strengthening applicable nutritional criteria, and pursue continued dialogue with relevant stakeholders.
13 In order to allow for adjustment of media buying practices and licensing agreements, individual companies will be
granted a transition period not exceeding one year, i.e. until 1 January 2013 at the latest, provided this is stated clearly in their individual corporate commitment published on the EU Pledge website.
20
34
Annex II - BDRC Compliance Monitoring Report 2011 – Presence in Primary
Schools
49
