Day 055 - 25 Nov 94 - Page 36


     
     1   Q.   Is this 89 per cent, or 11 per cent did not comply, is this
     2        following a complaint, or just generally did not comply
     3        with their guidelines?
     4        A.  No.  This was the ASA's own monitoring.  The ASA has,
     5        as I said earlier, recognised that it should carry out some
     6        of its own monitoring, and not just rely on complaints.
     7        I think there are particularly strong reasons why that is
     8        important when it comes to nutrition claims.
     9
    10   Q.   So they checked 138 food and drink advertisements in print
    11        and found that 11 per cent of them fell outside of their
    12        guidelines, in their own interpretation?
    13        A.  Yes, in relation to nutritional claims.
    14
    15   Q.   They thought that was a good -----
    16        A.  Well, the interpretation that is given in point 1 of
    17        the summary seems to imply a degree of acceptance of this
    18        level of compliance.
    19
    20        I think part of the problem is that the ASA's code needs to
    21        be strengthened and tightened in this area, and, secondly,
    22        there needs to be greater effective implementation of the
    23        code.
    24
    25   Q.   So, in reality, in April 1994, 11 per cent of the
    26        advertisements they looked at fell outside of their
    27        guidelines but were not complained about or dealt with?
    28        A.  Whether anyone else complained about them, I cannot
    29        judge, but from this paper here ---
    30
    31   Q.   They got away with it?
    32        A.  -- it does not appear that any action was taken,
    33        certainly none that is reported in this paper.
    34
    35        If I can refer to page 20, point 7 is talking about
    36        complaints that are generally received by the Advertising
    37        Standards Authority from members of the public or who else
    38        may wish to complain.  It compares the level of complaint
    39        relating to matters of nutrition, compared to the much
    40        higher level of complaints about issues such as quality and
    41        value for money.
    42
    43        It gives no further interpretation of this, which I think
    44        it needs, because I think this comes back to the point
    45        I made earlier, that it is much harder for people to
    46        understand where they might have been misled, for example,
    47        by a nutrition claim, if you are misled, you are misled,
    48        and you do not know that you have necessarily been misled;
    49        whereas it is obviously much easier to feel misled about
    50        quality or value for money. 
    51 
    52        Therefore, I do not think too much emphasis should be 
    53        placed on these figures to imply that there is not concern
    54        about nutrition.
    55
    56   Q.   Was that all you wanted to say on that document?
    57        A.  In relation to -----
    58
    59   MR. JUSTICE BELL:  If I may say so, these documents were
    60        produced in advance so that you and Ms. Dibb might have

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