At Global we have always placed our listeners at the heart of everything we do, and we engage with them regularly to understand what’s important to them.
As part of a project called the Consumer Trust Initiative, we looked at the impact audio ads with extensive terms and conditions (T&Cs) have on the listening experience, listeners’ trust of the media channel and their perception of the advertiser.
The results highlighted both the negative impact long T&Cs have on listeners but also on the consumers’ view of the advertised product.
Given the significance we have always placed on both the trust of our listeners and the important role of advertising within our business, we took the decision in February 2022 to support Industry Guidance and reduce the length of T&Cs on radio advertisements to a maximum of 8 seconds. Initially this only applied to Motor advertisers, but will be extended to all categories from December 1st 2022.
Charges apply
Consumers generally understand that there is always a price attached to products.
2 for 1 offers/cheapest item free
It is generally understood by consumers that this is how 2 for 1-style promotions work.
Subject to availability
Providing that the advertiser has good reason to believe that they have sufficient availability to meet the demand likely to be generated by the ad, this is in most cases not necessary.
Offer end dates
In most cases there is no need to include an offer end date providing that the ad is withdrawn a reasonable period before the end date.
Lists of exclusions
It is not usually necessary to list all the exclusions to an offer, instead a phrase such as ‘selected items’ are excluded would suffice.
Repeating information in tags
Where information is included in the body copy, repetition in a tag should be avoided.
Telecoms and broadband advertising
Whilst promotions and offers in this sector can be complex, there is no need to include information that doesn’t materially affect listeners ability to take up an advertised offer.
Previous pricing
Where ads quote a price and indicate that the price has been reduced, they are not necessarily required to give an indication of the previous pricing.
Contractual terms
Offers are often subject to contractual terms. However, providing that they don’t exclude some listeners from the offer, they normally don’t need to be include in an ad.
Subject to status/subject to credit check
Clearly information of this kind will need to be communicated to the purchaser during the sales journey, but it would not always be material information for the purposes of a radio ad.
Qualifications and clarification
Consumers understand that qualifying criteria apply to offers and it’s not always necessary to spell these out where they the condition can be easily complied with and doesn’t exclude any listener from participating.
to summarise
an example of the new guidance in practice
“Start your ‘Car Make’ love story today, for just £179 a month with 0% APR. Now with 5 year warranty.”
T&Cs
“PCP ‘Car Make’ Finance. ‘Car Model’. 24 months. Deposit £2685. Optional final payment £7714. Subject to status. Over 18s. Ts&Cs apply. Order by March 31st. Retail customers at participating dealers only. Warranty 100,000 miles or 5 years. Visit ‘CarMake’.co.uk/warranty. Search ‘Car Model’ offers.“
revised advert
“Start your ‘Car Make’ love story today, for just £179 a month with 0% APR. Now with up to 5 years warranty.”
T&Cs
“‘Car Make’ Finance. ‘Car Model’ . 24 months. Deposit £2685. Final payment £7714. Ts&Cs apply. Order by March 31st . Participating dealers. Search ‘Car Make’ offers.”
Listen to example of shorter T&Cs
“Global’s Consumer Trust Initiative is an excellent initiative that I strongly support. In my opinion, the FCA-Confirmed Industry Guidance document published by the Radiocentre, titled “Ensuring financial promotions for motors brands on radio are clear, fair and not misleading” gives advertisers both clear direction about how to reduce lengthy T&Cs as well as the confidence to ensure they will remain compliant in doing so. Those motors’ advertisers who can commit to following the Consumer Trust Initiative of having no more than 8” of T&Cs in their ads, whilst following the guidance offered in the document, will bring benefit both to themselves and to consumers.”
Brinsley Dresden, Head of Advertising & Marketing Law, Lewis-Silkin
“Trust in radio ads really matters. It’s clear that extensive T&Cs not only go down badly with listeners, but often do little to protect them. We welcome the Consumer Trust Initiative and won’t take action against shorter T&Cs that comply with the Ad Code.”
Guy Parker, CEO, Advertising Standards Association
“The AA, ISBA and ASA have embarked on a hugely important long-term commitment to rebuild public trust in advertising. Global’s ‘Consumer Trust Initiative’ to remove excessive T&Cs in advertising delivers on this objective – putting consumer’s interests at the heart of what they do. I urge all advertisers to embrace this initiative.”
Stephen Woodford, CEO, Advertising Association
“I believe the motor industry will welcome these new FCA approved guidelines as they will allow us to streamline the terms and conditions we need to quote when we advertise on radio.”
Paul Philpott, President & CEO of Kia Motors (UK)
