AUSTRALIAN MEDIA VEHICLES' STANDARDS

FOR ACCEPTABLE ADVERTISING

Herbert Jack Rotfeld, Colin Jevons, and Irene Powell

ABSTRACT: U.S. and Australian media vehicles are not required to publish or broadcast every commercial advertising
message submitted. To the contrary, owners and managers are free to designate anyone's message as unacceptable, and, in
fact, they do so, for many reasons. Building on the research literature on U.S. business practices, this paper reports results
of depth interviews with Australian media managers on their approaches to deciding what advertising materials to accept
or reject. The U.S.-based literature provides the basis for a model that illustrates the influences on media vehicles' decisions,
and Australian managers' responses indicate that it readily applies in their country as well. Overall, similar to U.S.
practices, the single most important reason for rejection of advertisements in Australia is a breach of taste, although
Australian vehicle managers more readily and visibly assert deference to the judgment of their more numerous and active
trade associations.

In Australia, as in the United States, no mass media vehicle—
no television station, cable or broadcast network, magazine,
radio station or newspaper—is required to accept any com-
mercial advertising material it does not wish to carry. With
some limited exceptions on broadcast political advertising,
mass media vehicles possess the right to reject any advertis-
ing matter they do not wish to carry, and in the United States,
some impose strong standards on which types of advertising
content they will accept for broadcast or publication (Rotfeld
1992, 2001; Weber 1991; Zanot 1985). Every rejection by a
vehicle manager has the power to influence or alter an adver-
tising campaign. Sometimes the vehicle's objections are mi-
nor, so the firm can make changes to the ad or commercial
without harming the message strategy. Of course, the adver-
tiser can decide to take the rejected advertising to another
vehicle, but only if there are others willing to accept it whose
audiences would meet the needs of the media strategy.
In the United States, with large numbers of vehicles avail-
able for marketing managers to reach their target audiences,
what one vehicle rejects, others might find to be readily ac-
ceptable (Parsons, Rotfeld, and Gray 1987; Rotfeld and
Abernethy 1992; Rotfeld, Abernethy, and Parsons 1990;
Wicks 1991a). Past research on formal and informal practices
apparently finds that the only universal is that many media
managers state a belief that what they do is universal.
Herbert Jack Rotfeld (Ph.D., University of Illinois at Urbana—
Champaign) is a professor in the Department of Marketing, Au-
burn University, Alabama.
Colin Jevons (M.Bus., Monash University) is a senior lecturer in
markering, Monash University, Melbourne, Australia.
Irene Powell (M.A., Monash University) is a senior lecturer in
marketing, Monash University, Melbourne, Australia.
This does not, however, mean that these media vehicle
management practices tend to be based on a concern for pro-
tecting consumers from deceptive advertising, as is done with
government regulations. In numerous surveys, the U.S. ve-
hicles' advertising managers repeatedly tend to state that their
most common reason for rejecting advertising is that the ad-
vertising style does not "fit" the editorial content. The actual
protection of consumers from harm is a general by-product of
their practices, whose primary intent is to deliver a vehicle
that audience members would wish to read, watch, or listen
to (see, e.g., Hayes and Rotfeld 1989; Parsons and Rotfeld
1990; Parsons, Rotfeld, and Gray 1987; Rotfeld and Abernethy
1991,1992; Rotfeld and Parsons 1989; Wicks 1991a, 1991b).
Rotfeld, Lacher, and Latour (1996) found that more than 7 1 %
of their respondent newspaper publishers indicated a strong
concern for whether ads might be deceptive, and had asked for
substantiation of statements. And yet, this too could be driven
by a desire that the vehicle advertising "fit" with the publi-
cation's overall content, since daily newspapers, unlike other
media forms, have their origins in concern for news and infor-
mation as opposed to the entertainment origins of magazines,
television, and radio.
A growing body of studies of U.S. media managers' poli-
cies and practices provides insight into the pragmatic reali-
ties of media influences on advertising content and the
limitations of media activities as a dependable force in con-
sumer protection. The present study extends this literature
to the Australian media market, a nation with fewer mass
media alternatives for advertisers and a more active collection
The authors acknowledge the assistance of Sarah Spencer-Matthews,
formerly of the University of Queensland, in the collection of original
data for this paper.

Journal of Advertising, vol. 33, no. 4 (Winter 2004), pp. 65-73.

© 2004 American Academy of Advertising. All rights reserved.
ISSN 0091-3367 / 2004 J9.5O + 0.00.
 Thejournal of Advertising
of self-regulation organizations that closely attend to media
practices.
U.S. Media Decisions, Self-Regulation, and Consumer
Protection
While the goal of government regulation of advertising by
the U.S. Federal Trade Commission (FTC) or Food and Drug
Administration (FDA) is aimed at stopping consumer decep-
tion, media policies do not necessarily share that same focus.
Each vehicle imposes its own standards that advertisers must
meet for the material to be acceptable: Some vehicles accept
virtually anything; many others limit their concerns to regu-
latory restrictions or potential legal liabilities (Campbell 1999;
Rotfeld 1992, 2001; Wicks 1991a, 1991b). But each vehicle's
manager or owner is free to direct these standards based on
his or her own assessments of the laws, audience values, and
what is ethically right and proper.
In general, the senior manager of the organization, usually
a publisher (in print media) or a general manager (in elec-
tronic media) sets overall policies. The manager's job perfor-
mance is judged by the overall profitability of the vehicle,
and he or she, in turn, is concerned about producing a vehicle
that both attracts audiences and interests advertisers (see, e.g.,
Hayes and Rotfeld 1989; Lacher and Rotfeld 1994; Rotfeld
1992; Rotfeld and Abernethy 1992; Rotfeld, Lacher, and
LaTour 1996; Rotfeld and Parsons 1989; Wicks 1991a,
1991b). Thus, advertising decisions are based on a cautious
concern for the impact of the advertising on the audience.
The managers' actions are comparable to those of editors, who
oversee the vehicles' news or entertainment content. Based on
policies or directions from senior management, advertising
acceptance decisions view the advertising content as part of
the overall vehicle content (Rotfeld 1992, 2001).
Television stations or cable networks rarely ask advertisers
for substantiation of claims (Parsons and Rotfeld 1990; Rotfeld
2001; Rotfeld, Abernethy, and Parsons 1990; Rotfeld et al.
I99O). Radio stations make such inquiries even less (Rotfeld
and Abernethy 1992). Daily newspapers are the only medium
that is more likely to list "misleading advertising" as its single
most common reason for rejecting advertising (Lacher and
Rotfeld 1994; Rotfeld, Lacher, and LaTour 1996). Some indi-
vidual media companies might state a strong concern for stop-
ping deceptive advertising, but more commonly, while the
vehicle managers probably would not knowingly carry ads that
actually harm the audience, their primary concern is to avoid
doing things that would cause readers to go elsewhere. In
other words, they are more concerned about the deceptions
that consumers might find on their own than they are about
misleading claims that readers, viewers, or listeners might
never discover. By the same process, managers may demand
that advertisers meet requirements that would never be re-
quired by government regulations, refusing certain subject
matter selling legal products or potentially offensive, but not
obscene, presentation styles (LaBarbera 1983; Rotfeld 1992,
2001, 2003; Rotfeld, Abernethy, and Parsons 1990; Rotfeld
and Parsons 1989; Weber 1991).
Within this context, faced with finite funds for advertis-
ing regulation, the FTC recognizes that every deceptive ad
stopped by the media is one less that might require the
commission's attention. Accordingly, it has been attempting
to encourage some of the vehicle managers to take a more
activist role in protecting audiences from deceptive ads. In
these days of the Internet and quickly exchanged informa-
tion, time and costs associated with checking out advertiser
claims is no longer a reason for ignoring possibly deceptive
claims. At the same time, however, managers' jobs are evalu-
ated by revenue and profitability, so even the best policy is
often driven by a mix of greed and fear—wanting the revenue
and not wishing to drive away the audience. And in market-
ing the vehicle, most managers are concerned about their en-
tertainment value, not a reputation for news and honesty.
Figure 1, which follows the style and format used by Rotfeld
(1992) to explain the limits of self-regulation, summarizes
past research on U.S. practices and illustrates the primary in-
fiuences on various vehicles' decisions for advertising accep-
tance found by various published studies. Past studies have
delineated how not all vehicles respond to all factors. Some
media vehicles accept almost anything. The greater the vari-
ety of alternative advertising vehicles for a marketing
manager's media plan, the more likely that an ad or commer-
cial will find outlets willing to accept it. Even potential law-
suits or restrictive regulations do not deter some managers,
since they may remain either ignorant ofthe law or brazen in
their belief that they are "safe" (for some unusual examples,
see Rotfeld 2001).
To an extent, vehicles' standards for acceptable advertising
do infiuence and alter some advertising content, including
both the claims advertisers make and the styles of presenta-
tion used. But as previously noted, an advertiser must alter
the advertising style or content only insofar as he or she wishes
to reach a particular vehicle's audience. A vehicle's advertis-
ing acceptance standards only prevent advertising claims or
styles from reaching its readers, listeners, or viewers.
Interrelated factors listed in Figure 1—offending the au-
dience, audience complaints, and damage to the vehicle's over-
all image—are those most commonly mentioned by media
managers as primary concerns for acceptance decisions. U.S.
media charge advertising rates based on the size of their audi-
ences, and since these factors might cause a loss of audience,
they could result in less income for the vehicle. Loss of adver-
tisers is another area of potential income loss for the vehicle,
although it is seldom reported as a basis for acceptance deci-
sions for competitors' advertising. More commonly, the pri-

FIGURE 1
Factors Influencing Vehicles' Decisions
to Accept Advertising
OX)
a Laws & regulations
••£ + Lawsuits
9i Vehicles' Clearance
Standards + Loss of advertisers
<U
Newspapers
Magazines + Damage to vehicle's
TV Networks & Stations
Radio Stations overall image
Cable TV Networks
+ Audience Complaints
VI
S Offending audience
O hour, it had only 60% of television stations and less than 50%
mary "consumer protection" activity seems to be primarily
driven by concerns for audience loyalty. The priority in ac-
ceptance decisions is to maintain an overall vehicle content
that engenders the maximum audience, which can later be
"sold" to advertisers.
Actual harm to the audience can only result from decep-
tive claims that audience members might not discover on their
own, so this becomes an influence primarily for those (appar-
ently rare) managers or owners who see service to the public
as a personal, and often altruistic, goal. "Laws and regula-
tions" can be real or threatened by government hearings, en-
forced, or merely on the books. In any ofthe above cases, they
are outside-the-firm threats to the organization, indicating
necessary directions for certain decisions. How readily a ve-
hicle responds depends on the manager's knowledge of laws,
ability to understand what the laws require, and a willingness
to comply (Hayes and Rotfeld 1989; Maitland 1985; Parsons
and Rotfeld 1990). Sometimes fear of a potential "lawsuit"
might engender special acceptance decisions (Weber 1991),
although there are anecdotes of U.S. broadcasters not altering
policies, even when required by law, until a listener or viewer
attempts to hold them responsible for their misfeasance or
nonfeasance (e.g., Rotfeld 1992, 2001; Rotfeld and Abernethy
1992; Rotfeld and Parsons 1989).
BUSINESS PRACTICES A N D
THE FORCE OF SELF-REGULATION
An inherent limit to any self-regulation effort comes from
the U.S. antitrust laws, or the comparable Australian trade
practices regulations. In either country, no business group can
force a mode of behavior on any of their competitors (e.g.,
Garvin 1983; LaBarbera 1983; Levin 1967; Maitland 1985;
Rotfeld 1992). Such restrictions would be improper restric-
Winter 2004 67
tions on competition. Therefore, the only power a self-regu-
lation code has on its members is the power of cooperation, or
any external force that might "encourage" cooperation, such
as regulations or laws that might be threatened. Indeed,
"Without the threat of government action, only the most al-
truistic of firms would ever pay heed to self-regulation direc-
tives" (Rotfeld 2001, p. 128).
Until 1982 in the United States, the National Association
of Broadcasters (NAB) had a code of good practices that was
encouraged by the Federal Communications Commission
(FCC), the body that granted licenses to broadcasters. Even at
the peak of its power, however, before it paradoxically ended
operations under threatened legal liability under the antitrust
laws for its limits on numbers of commercial minutes per
of radio stations following the code. Still, these were the larg-
est stations with the largest audiences, and the loss of the
code had many lamenting its loss as a force for consumer pro-
tection (e.g., Bosterhous 1983; Campbell 1999; Maddox and
Zanot 1984). And yet, one could also assert that the code was
more concerned with issues of taste than deception—such as
the use of live models in underwear advertising—since audi-
ence complaints were always a factor that would generate FCC
fines, or even a loss of license.
In some countries, various self-regulation bodies might have
ties to media trade associations, such that violation of the
code would result in most vehicles rejecting the advertising
(Boddewyn 1985, 1991; Harker and Harker 2000). In the
United States, however, such a relationship would probably
result in a per se violation of the antitrust laws, such that the
vehicles would be reluctant to enter a partnership with any
self-regulatory organizations. In Australia, such a partnership,
which also included advertising agencies, was allowed for many
years under a special exemption to their Trade Practices Act,
an exception that was ended in 1996 (see, e.g., Kerr and Moran
2002; Pearson 1996, 1999).
As in the United States, television broadcasting in Austra-
lia is more closely regulated than other media. Unlike the
NAB in the United States, however, Australian broadcast regu-
lations are directly involved with advertising issues. The Aus-
tralian Broadcasting Authority (ABA) administers the
Broadcast Services Act, which manages television and radio
licenses, advertising classifications, and the amount of adver-
tising content per hour. The ABA also administers all the
preclearance of television advertising to ensure that it meets a
minimum standard requiring compliance with both legisla-
tion and the Advertiser Code of Conduct. Television stations
are not legally able to run national advertising that has not
been vetted and given an authorizing key code number. Ad-
vertising to children is governed by the Children's Television
Standards, an additional requirement ofthe Broadcasting Ser-
vices Act.
68 The Journal of Advertising
Still, with a number of other Australian regulatory agen-
cies and consumer groups expressing concerns about "pro-
tecting" consumers, various media trade associations felt
impelled to have their own codes. For example, the Outdoor
Advertising Association of Australia (OAAA) developed
guidelines for all its members, and commented that there was
a risk to industry self-regulation if the industry were per-
ceived as failing to address concerns regarding advertising
standards (AANA/AFA/OAAA May 2001).
An important point of contrast is that the Australian mass
media system is smaller and narrower in terms of both num-
bers of outlets and owners than that found in the United States.
Rejection of advertising by a major vehicle could leave the
advertiser with few viable alternatives that would not have a
negative impact on the overall media strategy. The issue is
how readily Australian managers report priorities that are
different from those commonly reported in the United States.
METHOD
While studies of U.S. practices encompassed numerous large-
scale surveys, the majority of vehicle policies in Australia are
available from a much smaller number of contacts. Sixteen
telephone depth interviews involving 14 organizations were
undertaken, with multiple contacts required in the few in-
stances when more than one person was responsible for deci-
sion making for different vehicles in the same company. The
questionnaire that guided the depth interviews is available in
the Appendix.
Four of the organizations represented the commercial tele-
vision industry, five were drawn from the magazine publish-
ing sector, two were from newspapers, two were from the outdoor
media, and one was from radio. The titles of people with man-
agement responsibility for screening advertisements prior to
acceptance ranged from new business development manager,
editor, publisher, sales director, and direct sales manager. The
fourteen organizations willing to respond represent over 80%
of the media vehicle decision making in the country.
RESULTS
Policies and Priorities
All the respondents interviewed stated that their organiza-
tions were members of their trade association, such as the
Outdoor Advertising Association of Australia (OAAA), the
Commercial Television Association (CTA), the Newspaper
Advertising Bureau, the Magazine Publishers Association, and
the Federation of Australian Radio Broadcasters. And yet, not
all of these managers who claimed to administer these deci-
sions could always recall if they had a formal policy state-
ment. However, the ignorance went a step further in the
United States, when comparable managers cited trade rules
or codes, but then noted they had not read them lately and
did not know anyone on staff who owned a copy ofthe guide-
lines. Indeed, elaboration of details often revealed that these
managers did not really know what the code said.
The Australian magazine and newspaper publishers were
able to provide a copy of the information they give to poten-
tial advertisers who are preparing advertisements. An analy-
sis of these "policies" found that they were comparable to what
was reported in the U.S. print media studies, with the refer-
ences to advertising standards contained in contract form for
the standard terms and conditions (e.g., payment method,
artwork instructions, placement). They require advertisers to
sign a confirmation that their advertisement is in accord with
the legal requirements for advertising in Australia, such as
copyright law, the Trade Practices Act, and the Advertiser
Code of Conduct. The individual policies for magazine publi-
cations were essentially drawn from these legal entities, but
were accompanied by a much stronger focus on technical re-
quirements for reproduction, concerns about liability, and
ability of the advertiser to pay the bills.
The Australian outdoor media managers had written policy
documents that spelled out both legal and self-regulatory re-
quirements, a direct outcome ofthe close governmental scru-
tiny ofthe outdoor industry. The state government in Victoria
called for an inquiry into the portrayal of women in advertis-
ing, and the findings were reported in February 2002 (Victoria
2002), with recommendations subsequently incorporated into
the OAAA code of conduct.
Australian television broadcasters do not appear to have
formal advertising acceptance policies over and above the le-
gal requirements. This was asserted to be due to the perceived
strength ofthe regulatory system that all advertisements must
address prior to airing. Prior to submitting an advertisement
for airing on commercial television in Australia, the adver-
tisement must be approved by the Federation of Australian
Commercial Television Stations (FACTS, since renamed as CTA).
All advertisements that are screened and approved by FACTS/
CTA are given a key number, and it is an offense under the
Australian Broadcasting Services Act for an advertisement to
be accepted by a television station without this number.
One participant reflected that the FACTS/CTA approval
system was "fairly fail-safe," as the approval process also dic-
tates any particular conditions that an advertisement may have
in terms of airing. The participant stated that "an advertise-
ment is classified in the similar manner to our normal pro-
grams—if it is deemed unsuitable for children, then the
advertisement can only be aired after 20:30."
Of course, just because a commercial is approved does not
mean it will be accepted by the individual broadcast organi-
zations. One respondent made a point of stressing this per-
sonal power to veto an advertisement even if it has FACTS

approval, although she admitted that such actions have been
rare. The situation where she might reject an advertisement
would most likely be based on the time slot desired by the
advertiser and its fit with the audience, not potential decep-
tion, based on her experience and interpretation of commu-
nity values. The respondent acknowledged that "it is a gray
area . . . you will always get the 'ratbags' complaining."
("Ratbag" means "serial trivial complainers.") A different re-
spondent also believes that "FACTS occasionally gets it wrong."
For example, while they are allowed to show an advertisement
rated S (sex) between 11 P.M. and 5 A.M. local time, the particu-
lar television station would not run them prior to midnight,
and even then they are selective in terms of the program envi-
ronment. It should be intuitively obvious that this is less an
error by FACTS than it is the result of the manager's own
sense of how the commercial fits with the audience tastes.
The Australian print media—both newspapers and maga-
zines—mentioned that all ads are booked with the proviso
that the publisher reserves the right to reject any advertise-
ments. In addition, the industry trade body also provides guid-
ance over and above legal requirements of the various codes.
Print managers noted the Therapeutic Goods Code and the
Weight Loss Industry Code as being well known and as seen
to have the force of legislation.
In the United States, the vehicles and their trade associa-
tions state an expectation and desire that deception control be
managed by the government agencies (see, e.g., FTC 2002; Gal-
loway, Rotfeld, and Richards 2005; Rotfeld 2003). In the same
fashion, and despite claims of more extensive self-regulation con-
trol, Australian managers also focus on taste, not protecting the
vehicle's audience from deception, stating an expectation that
the advertisers will be compliant with the Trade Practices Act.
The concern is to avoid offending the audience, and reducing
its commercial value as a result, rather than to avoid mislead-
ing it. For example, one magazine's advertising manager said
that this publication would not accept advertisements from
dating services, a firm policy for the particular company, al-
though many of the other specific conditions are not written
down. In print media of magazines and newspapers, advertis-
ing sales executives are given delegated authority to make de-
cisions and will only refer "up to the editor when it looks dicey."
Decision Making
Respondents reported disparate views about who in the com-
pany was responsible for implementation of the company's
advertising acceptance policy. One respondent stated that it
is the responsibility of the production manager to check that
the client advertisement is suitable for publication and that
the "sales team just sells the space." Another respondent stated
that the salesperson should communicate the company policy
to the advertiser or advertising agency.
Winter 2004 69
What it comes down to at these Australian organizations
is a process that, on a day-to-day basis, sounds the same as
that reported in the United States. Most participants admit-
ted that, ultimately, the staff responsible for screening used
their judgment based on employees' perceptions of commu-
nity attitudes. Although a "check sheet is not used," it is seen
as part of the managers' role to decide on the acceptance of
advertisements, and these decisions are "based on common
sense," "knowledge ofthe Codes," and, in many instances, an
interpretation of what is "acceptable"; "it is the community
(that) sets the standards."
Audience Complaints
When asked about the types of complaints that had been re-
ceived about advertisements in their publications, one maga-
zine company stated that complaints from advertisers were
taken much more seriously than complaints from readers. The
advertiser is usually complaining about problems with its own
advertisement, however, such as mistakes in copy or position
of the advertisement.
Several magazine publishers reported very little knowledge
of complaints from consumers about their advertisements,
asserting that (1) their publications were "fairly conservative,"
and therefore did not suit potentially controversial advertise-
ments, however defined; (2) since the cost of advertising in
their vehicles is relatively high, advertisers did not want to
risk alienating readers or cause a delay in production; and (3)
"most advertisers are aboveboard anyway." The television
broadcasters were more aware of complaints, due to their re-
sponsibility to log and report all complaints as part of their
license agreements. Outdoor companies were aware of com-
plaints from consumers; they, too, log all their complaints
and could provide contact details for the Australian Standards
Bureau.
One participant who had had many years in the traffic de-
partment thought that violence, sexism, sex, nudity, and con-
cern for children would be the most common grounds for
problems. It was noted that sexism these days refers to sexism
against both males and females. Complaints against advertis-
ing can come from "both the sane and the ratbags"—not all
complaints are logical or unemotional. This perception by
the managers is upheld by the letters of complaint published
by the Advertising Standards Bureau that exhibit emotional
language indicative of strongly held opinions and beliefs (e.g..
Advertising Standards Bureau 2003a, 2003b). It should be
noted that complaints are not necessarily representative of
the population at large (as reported by Volkov, Harker, and
Harker 2002).
Several respondents noted what they felt were the limits of
their responsibility. For example, an interviewee said that it
is frustrating when a mother complains that her child viewed
70 The Joumal of Advertising
an inappropriate advertisement that was screened after 8:30
P.M., the time at which the code of practice assumes that chil-
dren cease viewing television for the evening. Another re-
ported that complaints are relatively common during times
when programs that have been rated "parental guidance rec-
ommended" or "M" ("mature audiences only") are aired. And
yet, the logic of the standards might be in error. The time slot
from noon to 3:00 P.M. Monday through Friday during school-
term time is rated "M," but this time slot poses a potential
source of complaints from viewers, as young children who are
not at school, kindergarten, or day care could be exposed to an
inappropriate advertisement. A magazine publisher reflected
on "Just how far are we supposed to go?" in checking advertis-
ing claims. The publisher was speaking specifically about the
recent increase in advertisements that include a Web address,
asking if the magazine would be responsible if the advertiser's
Web site contained potentially offensive material, even if the
advertisement in the magazine was all aboveboard.
Political opinion advertisements outside the formal elec-
tioneering period are uncommon in Australian television,
magazines, and newspapers; most election money is spent on
targeting voters in marginal electorates via direct mail. Re-
spondents' comments reflected this, although one participant
could recall that 18 months previously an advertiser was asked
to voluntarily withdraw its advertisement, as it was suppos-
edly disrespectful of the local State premier. Since stating cer-
tain opinions could offend certain audiences, it is no wonder
that many U.S. vehicles have a blanket ban on opinion adver-
tising, although apparently this is a nonissue in Australia.
Some respondents reported little concern about the poten-
tial of reader/viewer complaints, whereas others were much
more sensitive about the impact on their vehicle. This was
evident with one of the broadcast participants, who reported,
"Perhaps if excessive complaints were received, then it could
reflect badly on our company, but essentially, it is the adver-
tiser, not the medium, that they (the viewer) are annoyed with."
This view is not illogical; indeed, it is consistent with many
examples of audience reactions to offensive advertising in the
United States (see Rotfeld 2001 for some detailed examples).
Rationalization about not caring overmuch about receiving
some complaints is evident in the comments of the interviewee
who stated that it was common for a client to advertise across
all television stations, and therefore, "our station is in no more
hot water than the other stations." One participant did ac-
knowledge, however, that complaints that were numerous or
ofa high degree of severity would be investigated further.
FINAL CONTRASTS A N D
LOOKING TOWARD THE FUTURE
It should be noted that some published studies of self-regula-
tion both in the United States and other countries implicitly
presume a sense of altruism on the part of decision makers.
Effects or effectiveness is sometimes presented by counting
the types of advertising activities stopped. It is true that some
individual media owners in any country might be driven by
an altruistic sense of community service. But the media ve-
hicle managers make their decisions for business reasons, and
time and again, participants' responses indicate that more
pragmatic business considerations dominate. The important
point of Figure 1 and the present study is that the key issue is
not "how many" vehicles engage in certain types of decisions,
but rather more timeless insight into the business forces that
influence those decisions in both countries.
More broadly. Figure 1 is not tied to U.S. culture, but de-
scribes free-market decision making by managers, in which
advertising-supported media constitute a profit-driven busi-
ness. There is every reason to expect the Figure to readily
apply to many other countries with a market-driven media
system with limited government regulation.
While managers in both the United States and Australia
are averse to conflict, they would rather not be in the uncom-
fortable position of rejecting advertising revenue. In the
United States, to go beyond issues of "fit" with the editorial
content, managers rationalize that an uncertain "someone else,"
such as managers at other vehicles or the government, would
act on deceptions or other problems of audience protection
(see, e.g.. Parsons and Rotfeld 1990; Rotfeld 1992, 2001,
2003). In Australia, advertising managers say that they do
not want to go beyond the foundation of active legislation;
with the Trade Practices Act, the Broadcasting Services Act,
and the many and growing codes of conduct and prescriptive
guidelines, they can point to another authority that they can
assett is handling problems. Indeed, in Australia, media ve-
hicle managers believe that standards are formally regulated,
and that in the main, this provides sufficient protection. All
current outdoor advertising contractors are members of the
OAAA, and when the issue of the portrayal of women arose,
the industry body spoke on behalf of all its members and sub-
sequently adopted a code with which all will comply.
Managers in the United States and Australia are driven by
the practicalities of doing their job: "Attracting an audience
and selling that audience to advertisers." Collectively, they
are not driven by social policy, but individually, they have
their own opinions and beliefs about what is "legal, decent,
honest, and truthful." In both countries, the media market-
place is very competitive, with many vehicles looking to se-
cure diminishing advertising budgets. The pressure to secure
audience and advertising revenue takes precedence over what
is a small percentage of complaints compared with the vol-
ume of advertising carried by each vehicle.
The results of the interviews with managers responsible
for advertising acceptance for television and radio stations,
magazine and newspaper publishers, and outdoor media in-

dicate that the situation in Australia is similar to that in the
United States in that the single most important reason for
rejection of advertisements was a breach of taste. Australian
television companies have relied very heavily on rulings made
by FACTS/CTA, while magazines and newspapers, which also
reported rarely rejecting advertising, did so when the prod-
uct or the message was considered likely to conflict with the
values of the readership. The outdoor medium was unique in
that it rejected more advertising, but this was a result of the
current circumstances in adopting their new code.
And yet, in both countries, government agencies would
like media vehicles to do more to screen advertising for de-
ception. In recent years, this has come to a head with the
plethora of weight loss products in countries that both report
growing problems with obesity.
In 2002, with public hearings and a 2003 staff report,
the U.S. Federal Trade Commission had the vexing problem
of an inundation of patently deceptive weight loss advertis-
ing. To make matters worse from the point of view of both
the FTC and consumer advocates, the products might gain
additional unearned consumer credibility since a large
amount of the deceptive advertising appeared in reputable
and trusted magazines, newspapers, and television outlets.
At a workshop to encourage media vehicles to move to spot
and stop these deceptive claims (FTC 2002), the media man-
agers on the panel seemed reluctant, and even unwilling, to
take a leadership role and say they would try to stop accept-
ing the advertising (Galloway, Rotfeld, and Richards 2005;
Rotfeld 2003). This prompted one commissioner to pub-
licly express her dismay with the media managers and to
hint that the commission could take the unprecedented step
of holding vehicles liable for publishing or broadcasting the
patently false claims by the weight loss advertisers (Anthony
2003). The vehicles could have readily seen this comment,
coupled with other statements at the workshop, as a real
threat that the FTC had the power to enact (Galloway 2003).
The final staff report and decisions backed off from recom-
mendations of actually holding the vehicles responsible, and
the threat is believed to possibly encourage some vehicles to
at least stop carrying the most blatant of deceptive claims
for these products.
Similarly, in March 2004, Graeme Samuel, chairman of
the Australian Consumer Competition Commission (ACCC),
the government agency and industry watchdog that enforces
the Trade Practice Act, announced that it would be targeting
advertising agencies and media outlets to ensure that they
had proper procedures in place to prevent the publication of
misleading and deceptive advertising. The agency announced
that it would be targeting extravagant claims for weight loss
products, and the companies could be liable for fines in excess
of a million dollars (Hartley 2004). The vehicles have the
possible defense that they did not know or had no reason to
Winter 2004 71
suspect that the advertisement was deceptive or misleading,
but the view of the ACCC is that publishers and broadcasters
would have reason to be suspicious if the claims are not in
keeping with generally known facts.
In both instances, the threat of regulations could and should
be expected to cause changes in business practices, and per-
haps, at least in Australia, such changes could be fostered by
media trade associations.
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APPENDIX
4.
Telephone Questionnaire (Depth Interview Guide)
I am conducting some research on advertising acceptance prac-
tices in the ad industry in Australia. Are you the right person to 5.
speak to? [Or] Who do you think I should speak to? Please may
I ask you the questions just now?
6.
1. a. Who in your organization sets the policy to decide
which ads are acceptable?
b. Who in your organization is responsible for day-to-
day decisions?
c. Who in yout otganization has the final say?
d. Would you discuss any likely controvetsial ads with
the client and agency? 7.
2. a. Are there special guidelines for acceptance of ads for
certain product categories, such as alcohol, weight
loss, condoms, feminine hygiene, therapeutic goods, 8.
political opinion?
b. Are there special guidelines for acceptance of ads for 9.
different sites/time slots/ positions in the publication
(e.g., sealed section)?
3. a. Do you have a formal or informal policy for accepting 10.
or rejecting ads? '
Winter 2004 73
b. If formal, is this a written policy?
c. If yes, is it possible to receive a copy of the policy?
Are there any recent guidelines that have affected how
you accept ads? Portrayal of women/outdoor, motor
vehicles, and so forth.
Do you think that your medium is different from other
media? Outdoor/Television/Radio/Newspapers/
Magazines/Cinema.
a. What is the single most common reason for rejecting
ads?
b. What other reasons have caused you to teject ads in
the past?
c. What are examples of rejected ads?
d. What percentage of ads would be rejected, say, in the
past six months?
a. How do you handle complaints?
b. Have you ever asked an advertiser to prove the claims
made in an ad?
What other commercial pressures have an impact on
your acceptance policy?
Is thete someone else in your organization who also
deals with the acceptance of advertising that I should
speak to? Who?
What is yout opinion of the recent controversy over
specific ads?