Document Sample
					         BULLETIN No: 19

         Telephone: 020 7306 7743
         Facsimile: 020 7306 7737

         Issued: Monday 4 August 2003




How Television Advertising

is Controlled

The ITC is the statutory body created by the Broadcasting Act 1990 to
license and regulate commercial television in the UK. Its remit
extends to all commercially funded television services broadcasting
from the UK, including satellite and cable services. The Act requires
the ITC to draw up and enforce a code on advertising standards. The
ITC also has a duty under the Control of Misleading Advertisements
Regulations 1988 to consider complaints about misleading television

The ITC sets standards for television advertising through its
Advertising Standards Code. This is adopted and reviewed after wide
public consultation. The ITC also consults regularly with the
Government and has a duty to carry out any government directions
about categories of products and services which may or may not be
advertised. In addition, the ITC receives regular advice on advertising
standards from an external advisory committee comprising
representatives of both consumer and advertising interests.

The ITC enforces compliance through a combination of prevetting
requirements and direct intervention. It requires the television
companies it licenses to employ trained staff to check advertising
carefully before accepting it for transmission. In particular they are
required to satisfy themselves that any claims are accurate and, where
appropriate, to inspect documentary evidence or seek the advice of
independent consultants. The majority of television advertising is
vetted by a central body called the Broadcast Advertising Clearance
Centre (BACC) who act on behalf of a number of ITC licensees
collectively, including ITV, GMTV, Channel 4, Channel 5, BSkyB
and UKTV. In practice, most television advertising is submitted
initially in script form and clearance for film production is given only
when the BACC, or the individual company, is satisfied that there will
be no breach of the rules. Where there is doubt about interpretation of
the rules the television companies are encouraged to seek guidance
from the ITC. These procedures, which are more searching than those
applicable to any other advertising medium, ensure that the vast
majority of advertisements which appear on television do not breach
the rules. The ITC does, however, monitor the finished output closely
and where necessary intervenes to require non-complying advertising
to be withdrawn. A decision by ITC to suspend or discontinue an
advertisement has mandatory and immediate effect and there are
severe sanctions for non-compliance.

The ITC considers all complaints which it receives about advertising
and, where an investigation is necessary, requires the television
companies to submit background material to it promptly so that an
assessment may be made with a minimum of delay. All complainants
receive a personal reply to their complaint.

       1   Complaints of Substance

       8   Summary of Other Complaints

      11   Analysis

 of Substance

The following complaints appear to raise issues of substance in relation to the interpretation
of the ITC Advertising Standards Code.

         OFFENSIVE Toyota Corolla - keys
                   Saatchi & Saatchi Advertising
    COMPLAINTS FROM        216 viewers

         BACKGROUND        An advertisement for Toyota Corolla showed a number of couples at a 'key'
                           party. The women were selecting partners by picking car keys randomly from
                           a glass jar.

                           One of the women was noticeably heavier than the others. The men appeared
                           to be uncomfortable with the idea that she might choose them. However,
                           when the woman picked the keys to the Toyota Corolla, they all stood up.
                           The line 'Corolla. A car to be proud of' appeared on screen.

                  ISSUE    The majority of complainants believed this to be a negative portrayal of
                           overweight women. They saw the humour of the advertisement resting on the
                           fact that the men found the woman unattractive purely because of her size. A
                           number also argued that it was irresponsible - in the light of concerns about
                           excessive slimming and eating disorders - to imply that it was necessary to be
                           slim to be attractive. Some complainants also objected to the sexual innuendo
                           implicit in the subject matter, particularly at times when young children could
                           see it.

          ASSESSMENT       The BACC had approved the advertisement with an 'ex-kids' restriction,
                           meaning that it could not be shown around programmes made specifically for
                           children. It considered that the woman was attractive, was not shown as
                           being vulnerable, and was presented in a positive light.

                           Toyota said that it had intended to advertise in a light-hearted manner but not
                           in such a way as to cause offence to viewers. It had chosen a larger woman
                           for the role to 'broaden the appeal' of the advertisement, but had not intended
                           to discriminate against overweight women. It reported that research across a
                           cross-section of the public had not shown the advertisement to be offensive.
                           Both Toyota and the BACC were concerned that messages encouraging
                           people to complain to the ITC had been posted on a website and that a
                           number of complaints had come via this route.

                           The ITC noted that a minority of the complaints seemed to originate from this
                           website. The majority of complaints, however, did not appear to be

                           The ITC could see how the scene could come across as discourteous or rude,
                           but also noted that the woman was presented as attractive and confident. On
                           balance, it considered that the scene was essentially lighthearted and unlikely
                           to be capable of any identifiable harm or to cause deep offence. It considered
                           the 'ex-kids' restriction was sufficient. For these reasons, the ITC did not find
                           grounds to uphold the complaints.

          CONCLUSION       Complaints not upheld.
   OFFENSIVE Virgin Mobile - Hospital
             Rainey Kelly Campbell Roalfe/Y&R
COMPLAINTS FROM   49 viewers

   BACKGROUND     An advertisement for Virgin Mobile Text Messaging took the theme of
                  "finding work for idle thumbs". It showed various patients in an imaginary
                  "Sparta Hospital for the Bored". They were dressed in pyjamas and engaged
                  in various unproductive activities designed to kill time, such as spraying
                  water from a drinking fountain, repeatedly switching a light switch on and
                  off, and stapling part of a nurse's uniform to a table.

          ISSUE   The complainants objected to what they saw as a mocking portrayal of people
                  with mental health problems or learning disabilities and considered that it sent
                  out a false message about mental health issues. Three of the complaints were
                  from people with family members who had mental health problems or
                  learning disabilities. Two further complaints were from a mental health
                  worker and the manager of a mental health hospital. They considered the
                  portrayal outdated, likely to promote the view that those with mental health
                  issues were dangerous, and likely to discourage those needing help from
                  seeking it.

    ASSESSMENT    The BACC explained that it had worked closely with the advertising agency
                  to ensure that the advertisement did not appear to portray people with mental
                  health problems or learning disabilities. This had resulted in the deletion of
                  some scenes, brighter music and the title "Sparta Hospital for the Bored" in an
                  attempt to help counteract this impression.

                  The advertising agency stated that it had not intended to cause offence and
                  had sought to portray a general hospital environment rather than a psychiatric
                  hospital or any other kind of institution. It had taken steps to distance it from
                  a typical, modern-day hospital in the UK and intended that viewers would
                  laugh along with rather than at the bored patients and their acts of rebellion.

                  Virgin Mobile had also commissioned pre-launch research groups to explore
                  reactions to the campaign amongst people who worked in mental health care.
                  These groups did not interpret the advertisement as denigrating mental health

                  Although two complaints were from mental health professionals, the ITC
                  judged that it was the friends and families of mental health patients and the
                  general population who - without the benefit of professional training and
                  awareness - were more likely to see the advertisement as a negative portrayal
                  of mental health issues.

                  The BACC acknowledged that the receipt of the complaints suggested that the
                  measures taken had not been sufficient to prevent the advertisement being
                  associated with mental health issues or learning disabilities. The ITC agreed.
                  It considered that the cumulative effect of the scenes in the 60 and 30-second
                  versions of the advertisement gave an impression of people with mental
                  health issues or learning disabilities and required that these versions be
                  withdrawn. It did not, however, consider that the shorter, 10-second versions
                  of the advertisement containing single scenes had this effect and agreed that
                  they could continue to be shown.

    CONCLUSION    Complaints upheld. Breach of ITC Code Rule 6.6.

     HARMFUL British Heart Foundation
             Partners BDDH
COMPLAINTS FROM   16 viewers

   BACKGROUND     The advertisement showed children in everyday situations. A boy playing
                  football with his friends said, "I'm useless, I always get out of breath". A girl
                  playing chase said "It's not fair, I'm always it" and another girl, slightly older,
                  looking at her scar in a mirror said of it, "The older I get, the more I see it".
                  The endline read "Thanks to research an extra 3 in 5 children born with major
                  heart defects now survive. It's the emotional scars they need help with now".
                  Behind each child were masked images of themselves, which echoed their
                  words as they spoke.

          ISSUE   Viewers objected on a number of levels to this advertisement, in spite of its
                  purpose to raise money for conditions, which either affected them, or their
                  loved ones.

                  Five viewers reported that their children had suffered actual harm as a result
                  of the advertisement suggesting that it had actually made matters worse. One
                  said the advert singled out sufferers as people to be afraid of and that it
                  implied that their scars should be kept hidden, another said that his son now
                  feels that he's not as good as his friends. Another said, "I have a 9 yr old
                  daughter with heart disease and scars as shown. She has never thought of
                  herself as having a disability and had not worried about her scar, and certainly
                  not been prejudiced by it in any way. She saw this today and was upset that a
                  girl like herself with her condition was excluded at school by peers and that
                  her scar is something to be ashamed of. This is also going to have been seen
                  by her peers at school who have never treated her differently through careful
                  management by us, her family, close friends and school, this has all been
                  ruined by a thoughtless ad campaigning for more funding by showing these
                  'poor victims'".

                  Two viewers said the imagery of sad looking children being mimicked by the
                  masks behind them was very distressing and not at all sensitive to the feelings
                  of children suffering from congenital heart disease. A further two said they
                  were offended by the unsympathetic treatment of the characters. Seven said
                  that: it was harmful to so negatively portray sufferers - it did no good at all to
                  present them as "sad, sick or psychotic"; it was damaging to a child's outlook
                  on life to be presented with this bleak and depressing scene and that the
                  advert, rather than fight the resentment and prejudice British Heart
                  Foundation (BHF) claim to be working against, was likely instead to foster it.
                  It was also suggested that the advert could frighten children who have or are
                  about to undergo heart surgery as to what the future holds.

    ASSESSMENT    The advertisement was shown in the run up to British Heart Week (June 7-15)
                  but is no longer on air. The advertiser said its aim was to create awareness
                  about children with heart defects and to raise money to provide more nurses,
                  further research and more support for patients and their families. It said
                  research confirmed that children growing up with congenital heart disease
                  feel left out and as they grow up can be treated differently or bullied so the
                  advert aimed to deal with those tough issues relying heavily on the in-house
                  expertise of the BHF itself and input from affected families. Ideas for what to
                  include were collected from parents and relatives of sufferers. The script was
                  shown to relatives before filming and the feedback was positive. The agency
                  concluded that the script was a powerful, relevant and accurate way of
                  highlighting the issue of congenital heart disease and, specifically why
                  children with the disease need support.

                  The agency said that neither it nor its client wanted to offend or distress
                  patients or their families.

                  The ITC understands the wish to attract public sympathy for the plight of
                  these children, as well as the need to alleviate that plight in individual cases,
                  and noted that the advertiser conducted relevant pre-production research on
                  proposed scripts. However, TV advertising can be a powerful medium and,
                  unless scheduled restrictively, is usually seen by most viewers of all ages. In
                  this case, the advertising deliberately, and with the best of intentions, singled
                  out a group of children who can be identified by their physical problems and
                  who are quite often treated in unfortunate ways. (As the advertiser pointed
                  out to the ITC, one in three children with heart disease reported that they had
                  been bullied in school and some patients grow up with psychological and
                  emotional problems.) The ITC was in no doubt that the advertiser was
                  entitled to draw attention to problems these children face but felt that the
                  method chosen - overtly showing identifiable children being isolated - might
                  involve some risk of being counter-productive.

                  However, after judging the number and nature of the complaints, and taking
                  account of the advertiser's consultations, the ITC concluded that this was a
                  borderline case and did not uphold the complaints. Nevertheless, for the
                  future, the ITC advised BACC to avoid scenarios of this kind where the group
                  in question is known to suffer from various forms of discrimination.

    CONCLUSION    Complaints not upheld. Guidance given.

  MISLEADING Scottish Power
             The Bridge
COMPLAINTS FROM   Staff monitoring

   BACKGROUND     An advertisement for Scottish Power claimed that "the average customer
                  actually enjoys cheaper combined gas and electricity from Scottish Power
                  than from Scottish Gas". Onscreen text stated this claim was based on a
                  domestic customer using 20,500kWh of mains gas and 3,300 kWh of
                  domestic electricity annually.

          ISSUE   Centrica plc, parent company of British Gas Trading Ltd which also trades as
                  Scottish Gas, complained that Scottish Power had not used the industry
                  standard figure in its advertising. It explained that it believed the average gas
                  consumption figure that had been set by Ofgem was 19,050kWh, not the
                  20,500kWh quoted in the advertisement, and that if Scottish Power had used
                  this figure, it would not have been able to claim that it offered cheaper
                  combined gas and electricity because British Gas was cheaper.

                  The ITC was concerned that viewers might not be able to make a fair price
                  comparison with other suppliers if Scottish Power used a different gas
                  consumption figure in its advertising.

    ASSESSMENT    Scottish Power admitted that if it had used the 19,050kWh figure as the basis
                  for comparing the cost of domestic gas consumption, Scottish gas would have
                  been marginally cheaper in some areas. The ITC noted however, that this
                  would not have prevented Scottish Power from making the same savings
                  claim because it had been couched in terms of the "average customer" and not
                  all customers. As the claim was valid under both figures, the ITC did not
                  judge there were grounds to uphold the complaint.

                  On the issue of which figure to use, Scottish Power argued that there was no
                  industry standard set by Ofgem. It therefore chose to calculate its own figure
                  because it judged the 19,050kWh figure was out of date and not
                  representative of the figure relevant to a present-day domestic gas user. It
                  referred to correspondence from Ofgem and Energywatch to support its view.
                  This showed that the basis of the figure was unclear and that it had not been
                  updated since 1996.

                  Transco calculated an average gas consumption figure of 20,500kWH and
                  Scottish Power used this figure as confirmation of its own figure being up to
                  date. It judged Transco's figures were likely to be the most representative and
                  impartial because Transco was independent of shippers and suppliers, it was
                  the only gas transporter with a network throughout Britain and part of its
                  balancing work included being aware of domestic customer gas needs on a
                  daily basis.

                  The ITC contacted Energywatch independently to question the background
                  and accuracy of the 19,050kWh figure. Energywatch explained that following
                  an internal review of the domestic gas and electricity consumption figures it
                  was "currently of the view that there is insufficient evidence available at
                  present to support the revision of the gas consumption level that we use for
                  the purposes of our price comparison factsheets". It therefore planned to
                  write to suppliers in order to seek views on the continued use of the existing
                  consumption levels.

                  As part of its internal review, Energywatch discussed consumption levels with
                  Transco and found that Transco's figure (which Scottish Power had used to
                  confirm its own figure) was likely to include an element of non-domestic gas

                  The ITC considered that there was insufficient evidence to support the use of
                  either the Scottish Power figure or the figure recommended by Energywatch.
                  One figure contained an element of non-domestic gas consumption and could
                  therefore be inappropriate to use as a basis for advertising aimed at purely
                  domestic users. And the other figure was generally regarded to be out of date.
                  It therefore judged that the advertisement was misleading and should not be
                  shown again in its current form.

    CONCLUSION    Breach of ITC Code Rule 5.3.1.

  MISLEADING Lets Go Shopping
             Balance Bracelet

   BACKGROUND     An advertisement for the Balance Bracelet, an item of jewellery made from a
                  metal alloy, was shown on Let's Go Shopping. It featured testimonials from
                  people who had experienced problems with their joints, and claimed that
                  wearing the bracelet had changed their life and made them feel "more
                  energised". It stated that there was no scientific explanation for the bracelet
                  but claimed that such jewellery had been used since ancient times and had
                  been of benefit to many people.

          ISSUE   A viewer complained that the advertisement should not suggest that the
                  product could improve certain ailments and conditions unless there was
                  scientific evidence to prove that it would. He believed the advertisement
                  would mislead vulnerable people into buying the product in the belief that it
                  would improve their health and well-being.

    ASSESSMENT    Let's Go Shopping believed that the advertisement made it clear that the
                  bracelet was a non-medical product. The advertisement did not refer to any
                  specific medical conditions and the testimonials expressed each individual's
                  own experience – it did not promise that the Balance Bracelet would work for
                  all viewers in the same way. Let's Go Shopping stressed the availability of a
                  60 day money back guarantee for dissatisfied customers, but pointed out that
                  only 8% of orders had been returned since the product was first advertised in
                  the UK. It added that jewellery of this kind was based on ancient Chinese
                  principles of acupuncture and universal energy, and that similar bracelets
                  were widely available in chemist shops and health stores.

                   The advertiser declared that the Balance Bracelet was a non-medical product,
                   and that the customer testimonials made no claims that the bracelet had
                   alleviated specific conditions. This was noted by the ITC who remained of the
                   view, consistent with the ASA’s approach to print and other advertising for
                   such products, that a customer testimonial describing health benefits that
                   could be construed by a viewer as medical in nature constituted an implied
                   medical claim for a product. This was therefore unacceptable in
                   advertisements for products that do not have a licence to make the same
                   medical claim implied by the testimonial. The ITC concluded there was a
                   strong implication that it was possible to derive some kind of health benefit
                   from the product. It reminded Let's Go Shopping that the offer of money
                   back guarantees did not mean that unsubstantiated claims could be made
                   about the product. In the absence of independent medical evidence to prove
                   that the Balance Bracelet could improve general health and well-being, the
                   ITC judged that the advertisement was in breach of the ITC Code.

      CONCLUSION   Complaint upheld. Breach of ITC Code Rule 5.2.1 and 8.2.3.

MISCELLANEOUS Scheduling of Advertising

     BACKGROUND    In an edition of the series Smallville shown on E4 on 26 May, an advertising
                   break occurred in the middle of a critical scene.

           ISSUE   A viewer complained that this contravened the ITC's Rules on the Amount
                   and Scheduling of Advertising.

     ASSESSMENT    RASA rule 5.1 states that:

                              Breaks within programmes may be taken only at a point where some
                              interruption in continuity would, in any case, occur (even if there
                              were no advertising) and such natural breaks must not damage the
                              integrity or value of the programme in which they occur.

                   RASA rule 6.2 - concerning drama and situation comedy programmes states:

                              A break may be taken only when:
                              (i)       there is a clearly marked and dramatically significant lapse
                              of time in the action, or
                              (ii)      there is a complete change of scene, with a significant break
                              in the continuity of action, or
                              (iii)     in the case of adaptation from stage plays, the original
                              intervals in the stage play may be regarded as natural breaks.

                   E4 explained that programmes acquired from abroad arrive with the
                   advertising breaks that existed in their country of origin still intact. E4's
                   normal procedure is to close up some of these, but to use those that comply
                   with the ITC's rules on frequency of breaks. Unfortunately, on this occasion
                   it had not picked up that the break had taken place in the middle of a scene.

                   E4 assured the ITC that it would reiterate to its staff the need for breaks to be
                   taken only where there is a clear change of scene. The ITC judged that the
                   break taken on 26 May had breached its code.

      CONCLUSION   Complaint upheld. Breach of Rules 5.1 and 6.2 of the ITC's Rules on the
                   Amount and Scheduling of Advertising.

MISCELLANEOUS Scheduling of Advertising
              ITV 1
 COMPLAINTS FROM   43 viewers

     BACKGROUND    An advertising break was broadcast over the end of live French Grand Prix
                   coverage on 6 July 2003 affecting viewers in ITV1's Granada, Border,
                   Yorkshire and Tyne Tees areas.

           ISSUE   Viewers complained that they missed the outcome of the race because of the
                   commercial break.

     ASSESSMENT    Granada said that it had sincerely apologised to those viewers who had
                   contacted it direct. It explained that the Northern Transmission Centre (NTC)
                   transmitted the break in response to a 'pulse' sent by the London News
                   Network which was controlling the transmission of programmes to the ITV
                   network. The NTC quickly realised that the network was still broadcasting
                   the programme and cut back to it. However, twelve seconds later
                   transmission automatically reverted to the commercial break which continued
                   to run over the remainder of the race. Granada assured the ITC that it was
                   investigating the matter which it attributed to human error.

                   The ITC noted Granada's comments and that it extended its apology to all
                   viewers affected by the error, but nevertheless judged that the broadcast was
                   in breach of ITC Rules on the Amount and Scheduling of Advertising

      CONCLUSION   Complaints upheld. Breach of RASA 5.1 (placing of breaks).

                    Summary of

                    Other Complaints

                  Advertisements for the products or services listed below
                  attracted complaints which after preliminary assessment, did
                  not raise issues of substance requiring further investigation.

                  These included complaints repeating points already
                  considered and covered in previous summaries, as well as
                  isolated expressions of personal opinion or experience which
                  did not call into question the conformity of the
                  advertisements with the requirements of the ITC Code of
                  Advertising Standards and Practice.

                  Product or Advertisement                          Number of
       HARMFUL Audi A3 – Fire                                                2
                   COI Passive Smoking - Kids                              18
                   Ford Galaxy                                               1
                   Gordon's Gin                                              1
                   Halfords – chimps                                         2
                   Lynx - attract women                                      1
                   McVities AM Cereal Bites                                  1
                   NCDL Sponsor a Dog                                        1
                   Piriton – bubble family                                   1
                   Sky Digital (Flaunt) - Select-A-Beau                      1
                   Sunny Delight                                             1
                   Sure for Men - Kung Fu                                    1
                   Tango – Barrel                                            1
                   Tango – Miss                                              1
                   Vauxhall Meriva                                           1
                   Volvic – caveman                                          3
                   Walkers – competition                                     1
                   Walkers Doritos - noisy neighbours                        1

                  Product or Advertisement                          Number of
MISCELLANEOUS Heinz Baked Beans - Keep It                                    4
                   Hutchison 3 Mobile                                        1
                   Ideal World HS - Product                                  1
                   ING Direct Savings Account                                1
                   Samsung – ringtones                                       1
                   SMS Joke of the Day                                       1

             Product or Advertisement                        Number of
MISLEADING AA Breakdown                                               1
             BT Together - New Pricing                                1
             Camelot Jackpot                                          1
             COI - Direct Payment                                     1
             COI - road tax evasion                                   1
             Dolphin Bathrooms                                        1
             Epil Stop                                                1
             Esure Insurance                                          2
             First Plus                                               1
             Halfords - roofbox                                       1
             Halifax Building Society - Howard's Challenge            1
             Holiday Bookers - TEXT                                   1
             Ideal World HS - Product                                 1
             International Technology Exchange                        2
             Katrina Tarot Line                                       1
             Kodak High Definition Film                               1
             Lloyds Pharmacy                                          1
             Lynx - attract women                                     9
             McDonalds Happy Meals - Tweenies                         1
             Mecca Bingo                                              1
             Norwich Union                                            2
             NTL - home                                               1
             Nytol - Dreamland                                        1
             P&O Ferries - new ships                                  3
             Pizza Hut - Home Delivery                                1
             Shredded Wheat - healthy heart                           1
             Simply Shopping Product                                  1
             Sky - Introduce a friend                                 1
             SMS Joke of the Day                                      2
             Sunny Delight                                            4
             Telewest Broadband                                       1
             The Mortgage Lender                                      1
             Volvic - caveman                                         1
             Walkers - competition                                    1

             Product or Advertisement                        Number of
 OFFENSIVE 0800 Reverse                                               1
             118 - The Number                                         1
             Anadin Extra - Police                                    2
             Audi A3 - Fire                                           1
             British Heart Foundation                                 1
             BUPA - Mrs Hunter                                        1
             Buxton - backside                                        1
             Carte D'Or - Car                                         2
                       Channel 4 interactive - monkey                                   1
                       Citroen C5 - Medusa                                              5
                       COI - Benefit Fraud                                              1
                       COI - Benefit Fraud - Target                                     2
                       COI Passive Smoking - Kids                                       4
                       COI/ Drugs Awareness - Frank                                     1
                       Cornetto Soft                                                    3
                       EMAP Celebrity Promotion                                         2
                       Evian                                                            1
                       Experience Corps                                                 1
                       Fristi Fruity Yoghurt Drink                                      2
                       Halfords - chimps                                               18
                       Irn Bru - baby                                                  11
                       John Smith - Mum                                                 6
                       Lilt - Beach                                                     1
                       Lynx - attract women                                             2
                       Lynx Shower - stethoscope                                        1
                       Penguin Chukka                                                   1
                       Persil Tablets - seven dwarves                                   1
                       Phones 4 U - Washing machine                                     4
                       Renault Megane - Derriere                                        5
                       Sony Wega Theatre System                                         3
                       Stella Artois - Devil's Island                                   1
                       Stepwise Nail Product                                            2
                       Sure for Men - Kung Fu                                           1
                       Vauxhall Meriva                                                  1
                       Volkswagen Polo - Giants                                         1
                       Volvic - caveman                                                 2
                       Walkers Sensations - Bath                                        1
                       Wow camera                                                       2
                       Yes Car Credit                                                   1

    There were also complaints of a generic character referring to the following matters :-

                       Product or Advertisement                              Number of
MISCELLANEOUS Amount of Advertising                                                   5
                       Artist Separation                                              2
                       Inappropriate Breaks                                           1
                       Noise                                                          7
                       Scheduling of Advertising                                      3


                                               COMPLAINTS IN THE REPORT

                         Number of          Number of                Number of
                         complaints     advertisements     advertisements about
                                            referred to       which complaints
                                                             were upheld wholly
                                                                      or in part
      HARMFUL          51       (0)       19       (0)            1         (0)
    MISLEADING         54       (1)       36       (1)            2         (0)
     OFFENSIVE        367       (0)       41       (0)            3         (0)
MISCELLANEOUS          71       (0)       11       (0)            3         (0)
     UNKNOWN            0       (0)        0       (0)            0         (0)
                      543       (1)      107       (1)            9         (0)

                                                          YEAR TO DATE 2003

                         Number of          Number of                Number of
                         complaints     advertisements     advertisements about
                                            referred to       which complaints
                                                             were upheld wholly
                                                                      or in part
      HARMFUL         692       (0)      303       (0)           19         (0)
    MISLEADING       1186      (28)      776      (28)           75         (7)
     OFFENSIVE       3958       (1)      725       (1)           37         (1)
MISCELLANEOUS         278       (3)      149       (3)           18         (1)
     UNKNOWN           15       (0)       15       (0)            2         (0)
                     6129      (32)     1968      (32)          151         (9)

                 The numbers in brackets indicate Text advertisements. They are
                 extracted from, not additional to, the overall numbers.