How does the alcohol industry attempt to influence marketing regulations? A systematic review

Abstract Aim To systematically review, using a qualitative, narrative synthesis approach, papers examining alcohol industry efforts to influence alcohol marketing policy, and compare with those used by the tobacco industry. Methods Literature searches were conducted between April and July 2011, and updated in March 2013. Papers were included if they: made reference to alcohol industry efforts to influence (a) policy debates concerning marketing regulations, (b) new specific marketing policies or (c) broad alcohol policy which included marketing regulations; were written in English; and concerned the period 1990–2013. Alcohol industry political activity was categorized into strategies/tactics and frames/arguments. Data extraction was undertaken by the lead author and 100% of the papers were fully second‐reviewed. Seventeen papers met the review criteria. Results Five main political strategies and five main frames were identified. The alcohol industry argues against marketing regulation by emphasizing industry responsibility and the effectiveness of self‐regulation, questioning the effectiveness of statutory regulation and by focusing on individual responsibility. Arguments relating to industry responsibility are often reinforced through corporate social responsibility activities. The industry primarily conveys its arguments through manipulating the evidence base and by promoting ineffective voluntary codes and non‐regulatory initiatives. Conclusions The alcohol industry's political activity is more varied than existing models of corporate political activity suggest. The industry's opposition to marketing regulation centres on claims that the industry is responsible and that self regulation is effective. There are considerable commonalities between tobacco and alcohol industry political activity, with differences due potentially to differences in policy contexts and perceived industry legitimacy.

false alliances built through the creation of front groups and astroturf organisations [4].

Financial incentive or disincentive
Businesses seek to influence policymaking through a range of financial inducements and disincentives. Inducements range from campaign finance and other political donations, to more 'under-the-counter' practices, such as offers of employment to policymakers, gifts, and the provision of entertainment [4].
Financial disincentives recognise the structural dependence of governments on business and policymakers' assessment of their electoral success on good economic performance. Such disincentives can involve capital flight (companies moving operations overseas or, on a more modest scale, withdrawing from, for example, sponsorship contracts) and capital strike (where companies refuse to invest).

Policy substitution, development and implementation
In addition to financial inducements, offers of support (Constituency Building), and information subsidies, business actors can also provide policy subsidies, where alternative policies are developed as a substitute for proposed policies. Policy substitution is attractive to policymakers as it reduces the administrative costs associated with developing and implementing policies, whilst still appearing to meet their policy objectives. Voluntary codes represent the most obvious policy subsidy, although companies can also offer to develop alternative statutory (or other more formal) policies where policymaking capacity is weak. The risk of such policy subsidies for policymakers is that the alternatives suggested are less effective at promoting public health.

Legal
Business is likely to use or raise the prospect of legal action when proposed policies are imminent and other, less adversarial approaches have failed [5, p.23]. Litigation (and the prospect of litigation) work by raising the (perceived and actual) costs associated with implementing regulation, and underline the immediate fiscal advantages of voluntary codes and regulatory policies acceptable to the industry.
International trade and investment agreements [6] also represent an important means of challenging health measures. Shaping such agreements represent a strategically important way of remotely shaping health policy [6].  There's insufficient evidence that the proposed policy will work / marketing doesn't cause or change behaviour (it's only used for brand selection and capturing market share), so regulation will have no effect √ √ The health impacts of consumption remain unproven √ Data Extraction Table 4: Summary of studies relating to alcohol industry (AI) attempts to influence marketing-related regulation.

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
B&T Magazine, 2012 [7] Australia General marketing -A stoush has broken out between the newly-formed Alcohol Advertising Review Board (AARB) and the AANA, with the body representing some of the biggest advertisers in the country claiming that the AARB is attempting to introduce greater alcohol advertising regulation by stealth.
Jeremy Griffith (Corporate affairs director, Carlton United Brewers): As tempting as it is to allow the health lobby to decide what is funny and proper, we think the current approach to advertising self-regulation gets it right. The Alcoholic Beverages Advertising Code (ABAC) is robust and effective and meets with community standards. The health lobby's approach is to ban everything, and if it cannot be banned, regulate it severely. It pays no regard to whether the current system actually works. The ABAC is

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
well enshrined in the industry -from the creative and scripting stages to the filming and placement process. It achieves what it intends -to ensure that alcohol is marketed responsibly. As a result, only 4% of complaints received by the ASB each year relate to alcohol advertising. Most importantly, the system has teeth. As signatories to the code, when complaints to the ABAC are upheld, we pull those campaigns. This can cost millions of dollars. We always encourage responsible consumption of our beers, but we certainly won't step away from using humour or nice-looking amber liquid in carefully frosted glasses to sell it. Finally, we welcome anybody to visit us to review our ads and approval process to

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used ensure we are completely aligned with community standards.
Alina Bain (Director of codes, policy and regulatory affairs, Australian Association of National Advertisers): There is no need for greater regulation of alcohol advertising as there are already a number of regulatory protections in place in terms of messaging and placement of alcohol advertising. The current selfregulatory system is effective and underpinned by a responsive and transparent complaints handling system. A system that delivers responses to consumer complainants within 30 days and covers all forms of advertising, including new media. The Alcoholic Beverages Advertising Code

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
(ABAC) is co-regulatory with a government representative on the management committee. ABAC'S independent adjudication panel is led by former Attorney General Professor the Hon Michael Lavarch, and is run at arm's length from the industry. It should be noted that alcohol advertisements have to be approved against the code before they go to market, by an independent pre-vetter. The low level of consumer complaints about alcohol advertising demonstrates the system is delivering for the public. According to the Advertising Standards Bureau, alcohol advertising accounts for just 3.78% of all complaints received. for the industry's integral involvement in the policy process by citing its 'vested interest' in reducing alcohol misuse: 'The Government will encourage active participation by all levels of the beverage alcohol industry as a key partner in the policy formulation and implementation process. The beverage alcohol industry has a vested interest in ensuring that alcohol misuse is substantially reduced, and has a unique capacity to access those responsible for promoting and selling alcohol as well as to those who consume their products'.

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
Sector and Civil Society and representatives from the Beverage Alcohol Industry'. According to the proposal, the council will also be responsible for monitoring and for reviewing the National Alcohol Policy every 4-5 years. The policy drafts state the reason for the industry's integral involvement in the policy process by citing its 'vested interest' in reducing alcohol misuse: 'The Government will encourage active participation by all levels of the beverage alcohol industry as a key partner in the policy formulation and implementation process. The beverage alcohol industry has a vested interest in ensuring that alcohol misuse is substantially reduced, and has a unique capacity to access those responsible for promoting and selling alcohol as well as to those who consume their products'. Priority area four-patterns and availability-basically upholds the need to 'develop and implement a transparent selfregulatory system by the alcohol beverage industry' and conduct public education campaigns.
In this section there is also a mention of the need to regulate alcohol promotions concluding by subscribing to the preferred industry approach: 'The Government supports the need for self-regulation by the alcohol beverage industry as the most Non-compliance with the voluntary industry codes had already been raised by some industry members. A complaint with two TV alcohol advertisements that they claimed contravened both the industry code and the TV code, as outlined in a letter to the Minister for Health and Children, met with no satisfaction over a two-year period. The wider Drinks Industry Group of Ireland acknowledged to the Department of Health and Children that there was justifiable concern at the 'slippage' which had occurred in relation to the implementation of the advertising code and suggested that the new Advertising code (ASAI) was a solid base to move forward. However, the 'new' code the letter also stated that: "Diageo has welcomed the recent alcohol harm reduction strategy published by the British Prime Minister's Office. It seeks a partnership across government ... We believe such an approach should be considered in Ireland as opposed to what we perceive as the one-dimensional approach currently being pursued." Non-compliance with the voluntary industry codes had already been raised by some industry members. A complaint with two TV alcohol advertisements that they claimed contravened both the industry code and the TV code, as outlined in a letter to the Minister for Health and Children, met with no satisfaction over a two-year period. The wider Drinks Industry Group of Ireland

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used retained the clause, "advertisements should not be directed at minors or in any way encourage them to start drinking", which is extremely difficult to prove thus making it inoperable.
The drinks industry and advertising industries met the Minister within weeks to explain their efforts to improve self-regulation. In May 2003, the Taoiseach speaking at the European Brewery Convention in Dublin, outlined the proposed alcohol marketing legislation to protect young people. It included restricting alcohol advertising on public transport, in youth centres and at sporting events where young people are participants. He also indicated the legislation would restrict alcohol advertising both on TV with a watershed of 22.00 hours and in cinemas and that all promotional material would carry a health warning about the risks associated with alcohol....The Minister for Health and Children was critical of the sponsorship by Diageo of the Guinness All Ireland Hurling Championship, a popular national game, as sending out the wrong message to a society attempting to curb alcohol abuse and suggested that the GAA acknowledged to the Department of Health and Children that there was justifiable concern at the 'slippage' which had occurred in relation to the implementation of the advertising code and suggested that the new Advertising code (ASAI) was a solid base to move forward. However, the 'new' code retained the clause, "advertisements should not be directed at minors or in any way encourage them to start drinking", which is extremely difficult to prove thus making it inoperable.

Study Geography
What policy is the AI attempting to influence?

UK
General marketing Q308 -Are you saying that Tesco now puts health awareness information in their alcohol aisle?
Mr Beadles: Can I step in and say that the Wine and Spirit Trade Association working with the DrinkAware Trust, which is the industry-funded charity, developed point of sale materials which reflected the Chief Medical Officer's health advice and also gave sensible drinking tips for the industry. They were produced towards September and have rolled out in a number of stores. They are not in every store yet, there is no doubt about that, but there are a number of store groups that have developed them. It is an ongoing process and we will be building it.
Q314: Do you think it is all right to promote alcohol, and I am not saying that Tesco does this but a major supermarket did, at the end of a children's clothes aisle Q314: Do you think it is all right to promote alcohol, and I am not saying that Tesco does this but a major supermarket did, at the end of a children's clothes aisle Mr Beadles: I do not believe that it is appropriate to sell alcohol and to market it there. In fact, the industry codes on the subject say that alcohol should not be promoted alongside anything that would appeal to children. There will always be instances where store managers get it wrong, and we have dealt with a number of those over the past six months where consumers have complained to us that they think a product has been inappropriately placed, and in

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
Mr Beadles: I do not believe that it is appropriate to sell alcohol and to market it there. In fact, the industry codes on the subject say that alcohol should not be promoted alongside anything that would appeal to children. There will always be instances where store managers get it wrong, and we have dealt with a number of those over the past six months where consumers have complained to us that they think a product has been inappropriately placed, and in all instances we have stepped in and the retailer has removed and changed the product location.
Q388 : The other Jeremy, in relation to the Sheffield report.
Mr Beadles: We take the same view, and we think there are other economic studies by CeBR and Oxford Economics that I think should be taken into account by this committee. We certainly take the view that the people who misuse alcohol are the least responsive to price changes. We do not argue at all that there is a relationship between price and consumption, but we do think that there is a lot of evidence to all instances we have stepped in and the retailer has removed and changed the product location.
Q385 : Minimum pricing. This is for Everyone who wants to come in on this. The Sheffield report on minimum pricing, especially in relation to elasticity of demand for alcohol, Jeremy Blood: do you accept the findings of the Sheffield report? Would you be in favour of minimum pricing?
Mr Blood: We are not in favour of minimum pricing. I have read the Sheffield report. It draws conclusions about affordability and price. We accept some of the conclusions. Other independent economic advice draws slightly different conclusions from it. As with all research, there is a range of conclusions that can be drawn

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
suggest that there is not a direct link between price and alcohol misuse.
Q814: I imagine you are using these new media more and more. Is that growing? from what is a complex set of data. Why do we, in principle, not support minimum pricing?
We believe that where misuse is happening and where people are drinking more than is good for them or using alcohol in the wrong way, those are the people that will not change their behaviour if you apply minimum pricing, they will carry on misusing, and you will not address the proper concerns that society has got about the misuse of alcohol through that blanket approach Q388 : The other Jeremy, in relation to the Sheffield report.
Mr Beadles: We take the same view, and we think there are other economic studies by CeBR and Oxford Economics that I think should be taken into account by this committee. We certainly take the view that the people who

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
Mr Oak: Yes.
Mr Fennell: That is why we need multiple safeguards.
Ms Carter: Today we have touched on the challenge that all age related categories have and I do not think this is just the UK. The internet is global. Potentially, somebody could be sat in a living room in America and set up a website in the space of five minutes. That is why we created our own digital code two years ago in the absence of anything else. There has been some good work going forward since then but we would certainly welcome any more help in that area.
Q818: Mr Fennell, in what way does the Diageo code which I have not seen but which has been spoken of considerably this morning differ at all from the ICAP codes on advertising for alcohol?
Mr Fennell: It is consistent. The code in the exact form of words is a consistent code for Diageo around the world. The first provision in our code is to make sure that we comply with local regulation. The form of words and misuse alcohol are the least responsive to price changes. We do not argue at all that there is a relationship between price and consumption, but we do think that there is a lot of evidence to suggest that there is not a direct link between price and alcohol misuse.
Q418: Mr Beadles can start with this but it is really for everyone. For quite a long time now since there has been concern about excessive alcohol consumption, the trade has been interested in voluntary arrangements and voluntary agreements, saying that they want to do something about it. You will all be familiar with the recent KPMG evaluation of voluntary agreements, and they showed extensive breaches of the voluntary code. Why do you think these voluntary

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
the meaning you can draw from them is consistent on every item

Drinkaware Trust
The Drinkaware Trust (Drinkaware) is an independent charity established in January 2007 as a UK wide, public-facing body with the objective of positively changing public behaviour and the national drinking culture to help reduce alcohol misuse and minimise alcohol-related harm, funded by voluntary donations from across the alcohol industry.
There is continued debate about the most effective methods of reducing excessive alcohol consumption. Legislation, regulation, self-regulation and enforcement all have an important part to play. However, education should always have a central role.

National Association of Cider Makers
It is misplaced to focus on the availability and approaches fail?
Mr Beadles: I do not think they fail, firstly. I think KPMG actually showed a lot of very good practice. I think the issue with a totally voluntary approach is that it only applies to the people who are in and sign up to it. When we looked at the businesses from an offtrade perspective, which, therefore, would fall within our membership and the producer side and their compliance, their compliance level was very high, but when you are trying to take that voluntary approach down to small independent businesses and people who are genuinely not interested in this stuff, then it is very tricky. I think a voluntary approach has an advantage. It tends to be faster and it gets to the core of big business quicker, but it is not going to ever get overall Mr Lewis: The Portman Trust has made no suggestion that it will reduce its commitment. We always hope that it may increase it. An important point to dwell upon for a moment is that the trust is an independent organisation with a very specific remit which is to provide information and education. It is evidence-based so that the consumers of alcohol and other interested

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used of The Portman Group; and -an industry-wide significant new social marketing partnership, aiming towards changes in attitudes and behaviour among certain target groups in the UK.

Scotch Whisky Association and the Gin & Vodka Association
We believe in a targeted approach aimed at "at risk" populations. We consider that working in partnership with all stakeholders is fundamental to tackling the issue and that education coupled with robust enforcement and responsible marketing and promotion are key elements to creating and underpinning a culture of responsible drinking.
Education in its widest sense is fundamental to a better appreciation of the risks associated with the misuse of alcohol. It can be used to target a range of problem drinkers: Alcohol education should be introduced in schools at an early and formative age and be a compulsory part of the curriculum and we welcome the DCSF's parties can make informed judgments about how they use it. The question sometimes raised is whether that is possible when the funding comes from the alcohol industry and we have on our board people who are employed by it, but the trust does defend its independence with great rigour. We view the presence of people on its board from the alcohol industry as helpful because it brings a considerable amount of expertise, but they are in a minority. When they are on the board they are there to represent the interests of the trust, not their parent organisations.

Portman Group
We consider, however, that better advertising in order to encourage the consumption of one brand rather than another but then they deny that it encourages an increase in alcohol consumption overall. I just think it is very unlikely that that is true, but what do you think of it in the context of what we have just been talking about?
Mr Poley: ... To turn to the question of the advertising effect, there is a wealth of evidence to demonstrate that the predominant effect of advertising is to cause brand switching. Even the report from the University of Sheffield commissioned by the Department of Health last year found that the evidence for the effect of alcohol advertising upon consumption was relatively weak. At best it will have a slight effect.

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used education, providing early advice and support to problem drinkers... The industry has an obligation to market its products responsibly so as not to encourage their misuse. It has a further obligation to use its reasonable endeavours to educate consumers and proactively encourage responsible drinking.
We are committed to regularly reviewing our Code rules through public consultation involving key stakeholders to ensure that the Code evolves and that it is indeed offering a proper balance between protecting the public from irresponsible drinks producer marketing while at the same time allowing companies reasonable commercial marketing freedoms.

Wine and Spirits Trade Association
Studies have shown the importance of education from a young age and from a variety of sources. Positive messages must an advertising ban, one of our overriding thoughts would be that an alcohol advertising ban would not actually stop people going out to pubs on a Saturday night, having alcohol with their barbeques or dinner parties. So I think one has to look at the wider marketing mix of alcohol. Additionally there are other alcohol categories that are not big alcohol advertising spenders but actually see strong growth. The wine industry would be an industry in which we have seen some phenomenal growth in the last 15 years but in relative terms has actually been a small alcohol advertising spender. So you have seen that there are lots of different dynamics in the marketing mix that could affect that. So we would say that you would have to look at all the elements together and an advertising ban would not

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
not only come from teachers and public health campaigns but from friends and family. Family attitudes have also been shown to be important in prevalence of drinking.
Increasing consumers' knowledge and appreciation of alcoholic products, through tastings and education courses also plays an important role in ensuring people drinks for the right reasons and do so in a healthy way. Wines and spirits can be a fascinating area of interest and teaching consumers to appreciate this is a more effective way of encouraging mature attitudes to alcohol than by demonising it through measures such as separate checkouts and tobacco style health warnings.
Providing information to the consumer is a key part of changing culture and to this end, the drinks industry fund the Drinkaware Trust

SABMiller
SABMiller is proactive in providing consumers with accurate and balanced really help. We would also be worried about the potential unintended consequences of that and might it push some producers to shift some of that money in their competition to gain volume share into more price activity, not necessarily in terms of depth of deal but maybe frequency of it. consumer experiences that will result in positive posts. The kinds of action that we have undertaken in this area are encouraging consumers to attend Smirnoff events around the country, at which responsible consumption messages play a key part, and then subsequently post their comments, pictures and videos online on our official Facebook page, and hosting briefings for bloggers and providing them with exclusive information that they may choose to post in their blogs.

Portman Group
the Committee seems to be under the impression that there is a "regulatory gap" in respect of on-line marketing and sponsorship... I recognise that the regulatory system is complex but the fact is that all drinks producers' marketing

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
activity is subject to the same strict standards of regulation; there are no "gaps".
For historical reasons, three regulators are involved: Ofcom, the Advertising Standards Authority (ASA) and the Portman Group. The different regulatory systems, however, while they operate independently of one another, adopt similar standards and complement one another to ensure strict supervision of all drinks producer marketing activity... the Portman Group seeks to regulate any marketing which is not otherwise regulated by Ofcom/ASA

Constellation Europe
Constellation believes that the majority of the public in England, who consume wine, do so on a responsible and

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used enjoyable basis.
Wine suppliers like Constellation consider that they can play a market based role in encouraging a more responsible approach to alcohol consumption among the public, where this is desired.
Such a strategy entails investing in the category through brand building and consumer education in order to encourage consumers to trade up to better wines and with it drive a better drinking experience.
This move to adopt a different drinking behaviour would also have a positive impact on consumption and misuse. Similar strategies have been successful in the United States.

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
moves to further ban advertising and promotion of wine, rather to use marketing strategies to promote a more responsible approach to alcohol consumption.

Drinkaware Trust
The Drinkaware Trust (Drinkaware) is an independent charity established in January 2007 as a UK wide, public-facing body with the objective of positively changing public behaviour and the national drinking culture to help reduce alcohol misuse and minimise alcohol-related harm, funded by voluntary donations from across the alcohol industry.
There is continued debate about the most effective methods of reducing excessive alcohol consumption. Legislation, regulation, self-

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
regulation and enforcement all have an important part to play. However, education should always have a central role. At the root of the alcohol misuse problem in the UK is behaviour ingrained in our culture for thousands of years. The public cannot be expected to accept attempts to change these deep-rooted social habits without clear information about the extent of the problem, and how it applies to them.

Molson Coors
It is our view that our marketing and advertising practices, whilst constantly under review, demonstrate our determination to behave in a responsible manner.
We do not know definitively whether the introduction of minimum pricing in the United

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
Kingdom is the right way to go. As Committee Chairman, you will be well aware of the very diverse views on this subject. Price is, in our opinion, certainly not a sole or decisive factor in addressing alcohol abuse . Certainly there are no single measures that, by themselves, will solve the problem.
... while we generally do not support Government price controls, we believe that social reference pricing may be helpful in the exceptional case of extremely low prices in the UK. To this end, I have made a number of public comments suggesting that a more detailed examination of the issue of minimum pricing would be desirable and that we would wish to take an active part in such consideration.

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
Molson Coors is a family brewer, I am a family man, behaving properly is an integral part of our collective and my personal commitment to operating to the highest standards. My Company and I are proud of our product and will champion it wherever we can. Part of that championing is to make sure that we actively seek new ways of ensuring that our product is always consumed responsibly. I am very pleased to be able to take this opportunity, on behalf of my Company, to offer every assistance to your Committee in its work.

National Association of Cider Makers
A review of published reports in the public domain produced by the UK Government and other bodies, quite clearly demonstrates that no one

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
alcoholic drink is responsible for alcohol misuse-misuse is caused by certain drinkers who clearly misuse alcohol and by some under 18s who are clearly breaking the law. This therefore is not a problem about problem drinks but about problem drinkers.
It is misplaced to focus on the availability and affordability (price and promotion) of alcohol as the sole and root cause of misuse. The real drivers behind harmful drinking, binge drinking behavior and under 18's alcohol misuse tend to get overlooked as a consequence. This means adopting or calling for a combination of long-term measures such as improving education, awareness campaigns, etc and short-term measures which can also be effective such as enforcing the

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
legislation that already exists.
NACM acknowledges that Government has committed resources to initiatives in this area as indeed has industry. NACM is a supporter of the Drinkaware Trust and of "Project 10" a £100 million (over five years) industry education initiative.
It is important to bear in mind that the distinction must be made and maintained to ensure that whatever means are introduced they are targeted at preventing harmful drinking without punishing the majority of people who drink responsibly. The industry is concerned that the introduction of measures that have a broader impact and go beyond targeting problem drinkers will bring with it unintended consequences.

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
To this end industry has a legitimate role to play in working with Government in reaching solutions.
NACM firmly believes that any policy considerations, by the Government, to address the specific misuse of alcohol by problem drinkers, should be: Notwithstanding these shortcomings ScHARR has failed to recognise that promotional activity provides a direct and more effective way to introduce consumers to new products and product variants. Restricting promotions will inhibit new product introductions. The average strength of cider in the UK has reduced. There are also plans to introduce into the UK market significantly lower strength cider but before the product is put on sale more widely it is being trialed/promoted in a limited number of retail outlets. However, without the ability to promote such new products, producers will not be able to introduce them to the public at large. Of concern is that inevitably the market will stagnate and will become

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
characterized by lower quality and cheaper products.
Advertising is already strictly regulated. NACM does not believe that any further restrictions on advertising will address any particular misuse issues. The consequences of further restrictions will be to shut down a further avenue for bringing to market newer and better quality products.
The Sheffield University review failed to provide compelling evidence that would warrant the Government to introduce controls on promotions and advertising. The review cited publications and references making causal links but some of these documents have not been peer reviewed. NACM reiterates its position that evidence should be robust. Penalising the industry and the general population is not an appropriate way forward in either seeking to bring about the desired changes in reducing alcohol harm or dealing with alcohol misuse (the problem drinkers).

As mentioned above members
Furthermore before any action is considered with regard to promotions and advertising it is vital that research is undertaken that is situationally relevant to the UK to avoid illconsidered policy proposals:

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
proposals that could undermine efforts to promote a cultural change if new products are not provided a route to market.
To restate, there are no problem drinks, only problem drinkers and therefore measures need to be targeted at these misusers. Furthermore NACM believes that the panoply of powers available to the police and local authorities should be used much more effectively both against individuals who misuse alcohol and those who willfully seek to break the law in obtaining alcohol underage, as well as against those retailers who sell alcohol irresponsibly.

Diageo
As a leading premium drinks producer, we recognise that responsible drinking is

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
important both to our business interests and to society's interests, and that we have a role to play in raising awareness and seeking to influence attitudes and behaviour among consumers of our products.
We believe that alcohol policy should be fair, effective, proportionate, consistent and evidence-based, and that it should not have unintended economic or social consequences. We do not believe that effective alcohol policy automatically or necessarily involves new legislation or regulation. We have identified three key priorities for responsible drinking within Diageo: -set world-class standards for responsible marketing and innovation; -combat alcohol misuse,

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
working with others on initiatives to reduce alcoholrelated harm; and -seek to promote a shared understanding of what it means to drink responsibly. This is underpinned by our use of our marketing insight and skills in an attempt to transform consumers' attitudes to alcohol.
We hope that the Government will continue to consider coregulation in delivering a mandatory code as well as respond positively to the other initiatives outlined in this submission, and that other stakeholders will also act, so that we can have a positive, collective effect in raising awareness and shifting attitudes and behaviours on alcohol and reducing alcohol misuse among the specific minority groups most at risk of

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
alcohol-related harm.

Scotch Whisky Association and the Gin & Vodka Association
The Scotch Whisky Association (SWA) and Gin & Vodka Association (GVA) are committed to working in partnership with Government and other stakeholders to tackle alcohol misuse. It is the minority that misuse alcohol. Adoption of a blanket "onesize" fits all approach does nothing to support the responsible majority-whether consumer or trader.
We believe in a targeted approach aimed at "at risk" populations. We consider that working in partnership with all stakeholders is fundamental to tackling the issue and that education coupled with robust enforcement and responsible marketing and promotion are

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used key elements to creating and underpinning a culture of responsible drinking.
We recognise and share the desire to tackle alcohol misuse. Indeed, the SWA and the GVA have been active in promoting responsible drinking for some 40 years. The alcohol industry-alongside other stakeholders-clearly has a role to play in encouraging and promoting the responsible consumption of its products to protect the long-term sustainability of the industry.
The drinks industry has a long history in promoting responsible drinking... Both Associations and our members are committed to helping foster a step change in cultural attitudes to the consumption of alcohol in the UK, which recognises that responsible, moderate consumption is part

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
of a modern, healthy society and that alcohol misuse is unacceptable.
Tackling alcohol misuse and achieving cultural change in attitudes to alcohol requires a long-term commitment, close collaboration and a concerted effort by a wide range of public and private stakeholders. It requires tough enforcement of existing alcohol laws, a sound regulatory framework, as well as an innovative approach to social marketing which reaches the right sections of the population. We welcome the government's decision to consult on its alcohol strategy and look forward to responding to the forthcoming consultation on the Government's proposed mandatory code of practice on alcohol promotions.

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used drink responsibly. We believe that an approach targeting "at risk" populations and potentially harmful contexts and drinking patterns will be most effective.
We embrace a partnership approach with Government and all stakeholders, focusing action on evidence-based measures. Such an approach breaks down barriers between the various stakeholders, fosters co-operation and allows the different stakeholder groups to share their experiences and build on best practice.
A fundamental deliverable from producers is responsible marketing and promotion of their brands. Advertising, promotions and sponsorship are a legitimate part of commercial activity in every industry. They play an

Portman Group
The Portman Group (TPG) was set up in 1989 by the UK's leading alcohol producers. Its purpose was to promote sensible drinking; to help prevent alcohol misuse; to encourage responsible marketing; and to foster a balanced understanding of alcohol-related issues.
A dilemma facing Governments is whether to use alcohol

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
policies to reduce the amount of alcohol that all drinkers consume in order to impact upon harmful drinking even though, by its very design, this approach penalises all drinkers alike. We believe that attempting to tackle problems through reducing per capita consumption (eg through taxation or restrictions on availability) is untargeted and unfair.
We strongly believe the focus should be on reducing alcohol misuse. It is possible, indeed very probable, that reducing alcohol misuse will actually result in a net decrease in the nation's alcohol consumption but that doesn't mean that reducing overall consumption is an appropriate goal in itself.
We consider, however, that better education, providing early advice and support to

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
problem drinkers, and a more robust approach to alcohol law enforcement across the UK would deliver further improvements.
The industry has an obligation to market its products responsibly so as not to encourage their misuse. It has a further obligation to use its reasonable endeavours to educate consumers and proactively encourage responsible drinking.
Drinks producers are comprehensively regulated by the BCAP/CAP Advertising Codes (overseen by the Advertising Standards Authority) and the Portman Group's Code of Practice on the Naming, Packaging and Promotion of Alcoholic Drinks. These codes (except for the BCAP Advertising Code) are self-regulatory and are

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used therefore sometimes referred to as "voluntary". This term needs to be clarified, however, as it is potentially misleading. The codes are voluntary in so far as the industry has volunteered to impose the restrictions on itself. As is explained below, however, compliance with the codes is mandatory; there is no opt-out for any drinks manufacturer. Some commentators claim that the problem of alcohol misuse in the UK is made worse by the price is manipulated to encourage sales. Pricing is, of course, controlled by retailers

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used not producers. Producers are nonetheless interested in the way in which their products are priced and promoted by the retailer. In general, we do not accept that price is the main contributory factor in harmful drinking.
Price and total consumption are undoubtedly closely related in that price hikes will usually lead to a fall in a nation's consumption. But the effect of price rises on the behaviours of the heaviest drinkers is ambiguous. There are nonetheless some specific pricing tactics by retailers, such as below-cost selling and volume-related discounts, which raise potential concerns. The Portman Group, however, is unable to offer any regulatory intervention to prevent such tactics or any other aspect of retailers' pricing structures.

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
Furthermore, retailers themselves may find it difficult to self-regulate on pricing because of fears of breaching competition law.... In the offtrade, however, the purchase of extra volume does not necessarily impact on drinking patterns; instead, consumers may choose to store their purchase and consume it at their leisure over weeks or months. For this reason, we are not convinced that action is required to curb volumerelated discounts in the offtrade. Any restriction on volume-related discounts in the off-trade risks possible unintended side-effects. Retailers may compete instead by further reducing basic prices or there may be a move to larger-sized stock-keeping units (SKUs); either of these might undermine the intent of the restriction.

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
Educational Initiatives: The Portman Group and its member companies have pioneered a number of inspiring alcohol responsibility initiatives which include: Drinkaware website, labelling, Drinkaware Trust No single policy action would transform our drinking culture overnight. Instead, alcohol harm reduction success depends on strong leadership from Government and a properly co-ordinated approach involving the medical profession, teachers, those working in the criminal justice system, regulators, media, parents, retailers and producers. The effect of pricing, advertising and availability are insignificant next to the effect of cultural stereotyping, peer influence and role modelling... We strongly believe that, given

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
accurate and full information, the vast majority of consumers will make healthier lifestyle choices. With others, we need to use more forceful powers of persuasion. In some areas of the UK, the alcohol laws could be enforced to better effect.

Scottish and Newcastle
We are absolutely committed to working together with the Government, the public health community and industry colleagues to tackle the abuse of alcohol in our society and to promote the responsible consumption of our products.
S&N UK believes the most effective alcohol strategies should concentrate on tackling alcohol misuse and not consumption per se. Any measures which focus on total consumption obscures differences in how people

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
drink and the outcomes they are likely to experience.
S&N UK does not believe that new laws or codes are the most effective way to bring about change. There is already a full range of laws in existence to tackle disorder and sales to those who are underage or drunk. We believe strong and consistent enforcement of these laws will be the most effective way forward.
We strongly believe that industry can be a valuable partner in tackling alcohol misuse, by marketing its products responsibly, providing consumers with informationdemonstrated by our full compliance with the voluntary label-and delivering education and responsible drinking programmes.
However, integral to the

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
success of the strategy is the role of individual responsibility. From Government, to industry to the individual, all parties have a role to play.

Wine and Spirits Trade Association
It should not be overlooked that there is a significant body of evidence from many global studies that show that moderate alcohol consumption can bring a range of health benefits and therefore tackling alcohol misuse should not be to the detriment of moderate consumers.
There are difficult problems that link alcohol abuse with social deprivation, unemployment, poor education, poor housing, poor nutrition and other major social issues. As the availability and price of alcohol is the

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used same through the UK, these problems clearly have more complex causes than the freedom with which alcohol can be accessed. It is essential that the underlying causes of these problems be addressed and not solely the regulation of the alcohol industry.
A targeted approach such is necessary to address the minority that are misusing alcohol without penalising moderate consumers. Whole population approaches to alcohol that concentrate on restricting supply across the board may reduce overall alcohol consumption, but these reductions tend to take place among the wider population rather than the problem drinkers whose consumption puts them at risk of harm.

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
clearly a key principle when tackling alcohol misuse and one notoriously difficult to foster. We believe that this is best done by greater enforcement of the laws relating to alcohol, quality school education and public health campaigns to promote a responsible attitude to drinking.
Increasing consumers' knowledge and appreciation of alcoholic products, through tastings and education courses also plays an important role in ensuring people drinks for the right reasons and do so in a healthy way. Wines and spirits can be a fascinating area of interest and teaching consumers to appreciate this is a more effective way of encouraging mature attitudes to alcohol than by demonising it through measures such as separate checkouts and

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
tobacco style health warnings.
Industry has often shown that its initiatives are able to outpace legislation, as has recently been seen with the implementation of Challenge 21 and Challenge 25 policies, and we believe the Government can secure its policy objective in a more timely and cost-effective way by working with industry rather than against it. Government can support and encourage these voluntary initiatives by avoiding placing additional burdens on industry.
While industry is involved in a large number of voluntary schemes to reduce the harms caused by alcohol misuse and promote its responsible consumption, it also take seriously the responsibility of marketing its products in a way that does not encourage their Changing the culture of alcohol consumption in the UK is a complex task that requires the partnership of a range of stakeholders. There is no silver bullet that will solve the problems of alcohol misuse, but by pursuing evidence based policies that target harmful drinkers, addressing problems through better use of the legislation that already exists and by promoting responsible use of alcohol in the population through education, the Government, in partnership with industry and other stakeholders, will be able to make a impact.

SABMiller
In general terms, moderate The initial findings of the University of Sheffield's ScHARR Review of the Effects of Alcohol, Price and Promotion raised the concept of "floor prices". These have also been proposed by the

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
Scottish Government in their report Changing Scotland's Relationship with Alcohol. We consider these to be both disproportionate and unnecessary. Minimum prices interfere with the underlying principles of a free market economy. The process of setting minimum prices is arbitrary to which there is no end, and it is predicated on the improbable assumption that raising the price of alcohol will make the minority of drinkers who misuse alcohol and/or engage in anti-social behaviour act differently. Minimum prices are most likely to impact the drinking behaviour of those adults who enjoy drinking alcohol and who do so in a legal, moderate, and sociallyacceptable way. In much of continental Europe, the price of alcohol is far cheaper than in the UK but there are not the

Study Geography
What policy is the AI attempting to influence?
Tactics used Arguments used same problems; societal tolerance (or intolerance) of those who drink irresponsibly or illegally appears to be a greater determinant of the extent to which a country will experience alcohol harm than the price of alcohol. Thailand General marketing In 2006, alcohol industry representatives, together with the entertainment venues surrounding a University, declared a code of practice not to sell alcohol to students in uniform during the daytime. This was intended to demonstrate self-regulation as an alternative to the total advertising ban which was being considered at the time.
Many stakeholders can alter the implementation outcomes by acting as the co-implementers. These include the role of the alcohol industry and related sectors in marketing self-regulation, the alcohol industry as a partner of the DDD Foundations, and the media in public A decrease in alcoholgenerated benefits, of the negative impacts of alcohol policy particularly in economic terms, is a common policy discourse for the industry. For example, the CEO of an alcohol company claimed that a total advertising ban would create 100,000 unemployed: "These measures do not attack the root cause of the problem. They will destroy alcohol industry by the misconception that all beverages are bad and are the cause of all problems...

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
campaigns. However, many see that these approaches may be designed to divert policy direction and to promote the corporate image.
In many instances, alcohol entrepreneurs negotiated 'trade-offs' with policy makers, such as 'using sport as a hostage'. They threatened to withdraw sports sponsorship in retaliation for the advertising ban.
The Federation on Alcohol Control of Thailand (FACT) was established during the formulation process for the FDA advertising ban regulation, in October 2006. Therefore, it was clearly seen as a lobbyist from the beginning. Its members include alcohol producers, sellers and distributors, the Thai Retail Association, The Marketing Association of Thailand, the Thai Hotel Association, the Thai Restaurant Association, and the Tourism Association..... FACT opposed the regulation in an aggressive fashion, including warning on the impacts to employment, criticising it as rushed, fishy, and unfair. They also threatened to petition the Administrative court.
The advertising sector will lose 1.5 to 2 billion Baht (by the ACC Bill)... Related sectors such as bottle shops, restaurants and tourism will be affected by at least 10% of about ten billion Baht" (Suthabodi Sattabut -Assistant Manager Boonrawd Brewery) The alcohol industry used this position (advertising ban is counter to the concept of trade competition, individual freedom and trade freedom) to oppose the ACC Bill.
A group of alcohol importers protested to the Thai Government, claiming that the advertising regulations were contrary to the WTO agreement.
The alcohol industry have used the example of increasing overall consumption in some countries that have banned

Study Geography
What policy is the AI attempting to influence?

Tactics used Arguments used
Foreign alcohol entrepreneurs have had a more explicit role in the alcohol policy process including lobbying for their participation. They were key particiapants in the meeting of 30 entrepreneurs in July 2003 to oppose advertising regulation and were criticised for delaying the decision.
In mid 2006, the US Ambassador took tobacco and alcohol entrepreneurs to meet with the Health Minister. In late 2006, the French Ambassador together with a few alcohol companies submitted their request to delay the regulation of advertising: "The alcohol companies, including whiskey giant Johnnie Walker, said they wanted to have a say in the public hearings on the new Bill being drafter to completely ban all forms of alcohol advertising" [Minister of PH after meeting with US Ambassador and alcohol industry representatives, 2006].
In many cases, alcohol operators used windows of opportunity in the alcohol policy process to undermine their business opponents, for example by deviating policy direction during the advertising ban formulation to advocate for White spirits tax alcohol advertising to oppose such interventions. "We advocate for a self regulatory system among alcohol producers as we know that advertising bans are ineffective from experience of New Zealand, US, Sweden and Denmark" (an administrator of an international alcohol company, 2005) The alcohol industry claimed the partial advertising regulation was a failure and later called for its repeal. Netherlands General marketing In the current Dutch situation, happy hours and other alcohol discounts in the catering industry are subject only to self-regulation. The Dutch Foundation for the Responsible Use of Alcohol (STIVA), an organization of alcohol industries representatives, has formulated an Advertising Code containing rules for alcohol promotions. According to the Advertising Code, alcohol promotions are not allowed in premises where 25% or more of the visitors are minors. Nor are premises permitted to offer alcoholic beverages for free or to sell them for less than half of the normal price, to offer more than one discounted drink per customer, or to combine alcohol discounts with additional free gifts.

Explanation of systematic searches
Search string: (corporat* OR industr* OR compan* OR busines* OR firm*) AND (alcohol OR drink) AND (marketing OR advertis* OR sponsor*) AND (regulat* OR policy OR legislat*)