Action 5
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Advertising and Sponsorship
What is Action 5 about?
Action 5 is about harnessing the power of advertising to support consumer behaviour change.
Advertising and sponsorship in print and digital publications are powerful marketing tools as they place brands and products in front of a target audience.
Consumers do not always have the right information or knowledge to evaluate the sustainability of a product or service.
Publishers have some responsibility in ensuring ads that appear in their publications are not misleading and have the opportunity to support brand, products and services that encourage sustainable behaviours.
Why is it important?
Action 5 is essential to avoid any risk of greenwashing and misleading information in advertising.
Carrying advertisements or promotions for products or services that make unsubstantiated environmental claims may pose a reputational risk to publishers.
Promoting the principles of the Green Claims Code, developed by the Competition and Markets Authority (CMA) to ensure environmental claims are not misleading, is a way to ensure publishers work responsibly and ethically. Adherence to the Green Claims Code by publishers’ commercial partners also helps customers and consumers in making informed greener purchasing decisions.
How to tackle it?
Behaviour change can be encouraged by embedding sustainability into commercial teams’ processes to assess customers and advertisements.
Some of the enablers to do this are:
Support the Green Claims Code: Publishers should set an internal advertising policy based on the Green Claims Code to advise clients on curbing misleading green claims to their best knowledge.
Training: Publishers should ensure that commercial teams are equipped with the knowledge necessary to identify when a potential partner may pose a reputational risk due to their environmental performance and to recognise and prevent potential greenwashing when products/services are being advertised.
Resources
- Action 5: What is the Green Claims Code?
- Action 5: Proposed Publishers’ Sustainable Advertising Policy
- Additional training and resources:
Action 5: What is the Green Claims Code?
The UK Green Claims Code, developed by the Competition and Markets Authority (CMA) was introduced in 2021 and was designed for businesses to check whether their environmental claims about their consumer-facing products and services would be misleading as defined by British consumer law.
The guidance is designed to help businesses understand and comply with their existing obligations under consumer protection law when making environmental claims.
The Green Claims Code principles are:
- claims must be truthful and accurate
- claims must be clear and unambiguous
- claims must not omit or hide important relevant information
- comparisons must be fair and meaningful
- claims must consider the full life cycle of the product or service
- claims must be substantiated
References:
Other ‘Green Claims’ regulations and guidance:
- The Advertising Standards Authority (ASA) is the UK’s independent advertising regulator and an established means for enforcing the Consumer Protection from Unfair Trading Regulations 2008. It administers the requirements for advertising in the UK Code of Non-Broadcast Advertising and Direct and Promotional Marketing (the CAP Code) and the UK Code of Broadcast Advertising (the BCAP Code).
ASA has published an updated version of its Advertising Guidance – misleading environmental claims and social responsibility
The principles of the CMA guidance are intended to be consistent with the requirements of ASA’s Committee of Advertising Practice (CAP) Code.
- In March 2023, the European Commission put forward a proposal for a directive on green claims. The proposed directive would require companies to substantiate the voluntary green claims they make in business-to-consumer commercial practices, by complying with a number of requirements regarding their assessment (e.g. taking a life-cycle perspective).
Action 5: Proposed Publishers’ Sustainable Advertising Policy
Introduction:
Publishers should already have policies and/or other documentations that describe their values/core principles and that cover terms and conditions for advertisers and other business partners.
Some of these documents however do not currently greatly address requirements with regards to environmental sustainability. This Sustainable Advertising Policy document is not intended to replace any existing publishers’ own advertising policy, advertising terms and conditions, contracts, ethical policies or code of conducts. Rather it was developed for publishers to consider integrating environmental sustainability, when not currently covered, into existing policies/documents.
The PPA does not require publishers to use this document in its entirety but encourages its members to review it and add ethical and environmental sustainability requirements into existing policies.
Purpose:
The Sustainable Advertising Policy sets the organisation’s requirements with regards to ‘sustainable’ advertising. The aim is to ensure that advertising avoids greenwashing and promotes genuine sustainable products, services or solutions.
Publishers have the responsibility to ensure that their content and the ads they accept are not misleading. To do this, publishers should review their commercial partners and other stakeholders and work collaboratively with them to prevent greenwashing in ads and any other marketing resources.
This proposed sustainable advertising policy was developed to help publishers implement this.
The sustainable advertising policy covers online & printed advertising and any associated campaigns, awards, sponsorships and events.
The Advertising policy includes:
- Ethical Advertising Guiding Principles: The organisation’s aspirations in terms of sustainable advertising
- What the organisation expects from its commercial partners (e.g. clients and sponsors) and other collaborators (e.g. awards judges and entry participants, guest speakers)
- Checklist to assess stakeholders internally
- What the organisation expects from the ads it publishes (printed and online) and from award entries
- Decision tree to assess stakeholders, ads, awards, sponsorships and events
Ethical Advertising Guiding Principles:
Advertising, online or in print publications, at events or in any other form, must meet various legal requirements and comply with the Advertising Standards Authority (ASA) and the Committee of Advertising Practice’ Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (the CAP Code).
Ads must be clear, accurate and not misleading.
Ads that contain any ‘green’ claim(s) should be checked against the CMA (Competition & Markets Authority)’s Green Claims Code and the CAP Code and effort should be made to ensure claims are not misleading.
Ads should be legal, decent, honest and truthful.
Ads should be ethical, respectful of all people, inclusive and should not encourage, either explicitly or implicitly, any indecent or harmful behaviour.
Requirements with regards to commercial partners and other collaborators
Publishers expect their commercial partners and collaborators to comply with applicable environmental laws, regulations and standards.
Publishers expect their commercial partners and collaborators to work ethically and to take action to reduce the environmental impact of their work.
Publishers encourage commercial partners and collaborators to have a clear strategy to identify and eliminate or reduce harmful activities and to be transparent about their progress with regards to human rights and environmental sustainability.
Publishers may reserve the right to refuse ads from sectors that may be deemed to cause harm to people and/or the environment.
Checklist to assess stakeholders internally
Publishers deal with a wide range of stakeholders. Commercial partners can include customers and sponsors. Collaborators may include awards judges and guest speakers. Other stakeholders may include awards applicants.
It is important for publishers to check that the stakeholders they interact with are doing their best to work ethically and responsibly.
The PPA has developed a checklist for publishers to use internally in order to assess their stakeholders.
For collaborators such as awards judges and guest speakers, publishers should consider asking themselves four questions about the organisation that these collaborators represent, which they should be able to answer following short research.
For commercial partners such as customers and sponsors and for awards applicants, publishers should consider researching further to answer more detailed questions about their organisation.
Checklist to assess commercial partners (customers and sponsors), awards applicants and collaborators (awards judges and guest speakers) internally:
For awards judges and guest speakers, consider asking yourself the following questions:
- Does the organisation operate in a sector that is controversial and/or deemed to cause harm?
- Has the organisation ever been accused of greenwashing?
- Has the organisation or its product/service received negative press or been taken to court for an environmental matter?
- Has the organisation been linked to potential human rights infringement, either through its own activities or through its business relationships?
If the answer is yes to at least one of these questions, the stakeholder should be seen as high risk. If the answer to all is no, then the stakeholder represents a lower risk and can be approved.
For customers, sponsors and awards applicants, consider asking yourself the same questions as for awards judges and guest speakers and, if the answer is no to all, then also ask yourself these additional questions:
- Has the organisation set net zero targets or any other targets to reduce its greenhouse gas emissions?
- Does the organisation have a sustainability strategy in place and clear targets and KPIs?
- Does the organisation publicly publish sustainability reports?
If the answer is yes to at least two questions, the stakeholder represents a low risk and can be approved.
If the answer is yes to none or one question only, then the stakeholder represents a medium risk and a deeper assessment is recommended if the stakeholder is considered for an event, award or an ad that relates to sustainability.
Note: Best practice is to assess every partner and collaborator; however, publishers may not have the resources available to do this at this stage. In that case, publishers should first assess priority partners and collaborators.
As the process of assessing ‘higher risk’ partners and collaborators become more mainstream and automated, the PPA expects publishers to gradually extend this assessment to all stakeholders they work with and for all their brands.
What the organisation expects from their customers’ ads and from award entries
For customers’ ads:
When customers’ ads include environmental claims or give the impression (through the way the ad is presented e.g. product’s name, colour and images used) that the product, service, brand or organisation provides an environmental benefit, publishers expect these ads to comply with the UK Green Claims Code.
Therefore, when receiving ads’ propositions from their commercial partners, publishers will ask, when relevant, if the ads were assessed against the Green Claims code. If this is not the case, publishers will encourage their customers to implement a process to ensure their ‘green’ ads are assessed against it in the near future.
Publishers will review any assessments and/or any supportive documents from their customers before approving the ad. Publishers will also assess the ad against the Green Claims Code checklist. When no assessment was done by the customer, publishers will need to assess the ad themselves before publication.
Note: Publishers may not have the capacity nor sufficient knowledge of their customers’ products or services to assess ads against all the criteria listed in the Green Claims Code and in the associated checklist. However, publishers should assess each ‘green’ ad against the Green Claims Code as best as they can. When unable to assess some criteria or when in doubt, publishers should ask their customers to provide the required information.
Checklist to assess ads against the Green Claims Code
When making green claims, your business must comply with consumer protection law.
It is also essential to comply with any sector or product specific laws that apply to your product or service. Before making a green claim, you should understand how your product, brand or business has an impact, both positively and negatively, on the environment for its whole life cycle.
When making a green claim, your business should be able to answer ‘yes’ or agree to each of the following statements:
- The claim is accurate and clear for all to understand.
- There’s up-to-date, credible evidence to show that the green claim is true.
- The claim clearly tells the whole story of a product or service; or relates to one part of the product or service without misleading people about the other parts or the overall impact on the environment.
- The claim doesn’t contain partially correct or incorrect aspects or conditions that apply.
- Where general claims – for example “eco-friendly”, “green” or “sustainable” are being made, the claim reflects the whole life cycle of the brand, product, business or service and is justified by the evidence.
- If conditions or caveats apply to the claim, they’re clearly set out and can be understood by all.
- The claim won’t mislead customers or other suppliers.
- The claim doesn’t exaggerate its positive environmental impact, or contain anything untrue – whether clearly stated or implied.
- Durability or disposability information is clearly explained and labelled.
- The claim doesn’t miss out or hide information about the environmental impact that people need to make informed choices.
- Information that really can’t fit into the claim can be easily accessed by customers in another way, for example a QR code, website etc.
- Features or benefits that are necessary standard features or legal requirements of that product or service type, aren’t claimed as environmental benefits.
- If a comparison is being used, the basis of it is fair and accurate, and is clear for all to understand.
Source: CMA’s Green claims checklist
For sustainability awards:
Whether the awards entry is related to a product, an initiative or a business strategy, the Green Claims Code’s six principles apply. These principles as well as the checklist are a good way to assess the entry from a clarity and impact viewpoint and whether it is backed by credible evidence or not.
A simple decision tree was developed to summarise sections 3 and 4 of this guidance.