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Making the Case For Enhanced Advertising Ethics

How a new Way of Thinking About Advertising Ethics May Build Consumer Trust

WALLY SnYDER Institute for Advertising Ethics

This article presents the case to advertising professionals for the need to enhance advertising ethics in order to build consumer trust in the company and its brands. It cites research showing that consumers do not trust advertising much of the time. key ethical concerns are discussed, including childrens advertising, the blurring of advertising with news and entertainment, and behavioral advertising. In the end, it is the responsibility of the ad professionals to resolve ethical concerns proactively, and they must be encouraged to do so from the top down, and given clear permission to express their concerns.

InTRODUCTIOn The proposition is simple: the advertising industry will benefit from practicing enhanced ethics. And its professionals can be inspired to do so. Advertising is everywhere in the lives of consumersin the many traditional outlets and now online as marketers are working hard to connect effectively with consumers. And, in a reversal of roles, it is now the consumers who are in control of the commercial information they want and where they want to receive it. As one who has worked my entire career in the field of advertisingboth as a regulator and counselorI know how important advertising is to the economy and to consumer choice. In fact, the U.S. government and the Supreme Court have been active in protecting the right to advertise in a truthful manner. Yet, year after year,

the bottom of the list on honesty and ethics (Jones, 2007). From the hundreds of meetings I have had with marketers, agencies, and media companies, I know how dedicated they are and how hard they work for their companies and consumers. And, as I have introduced the important role that I see for enhanced advertising ethics, genuine interest has been shown in the topic, along with a willingness to learn how to advance their business and social responsibilities. How do we make the case for enhanced advertising ethics? How do we convince marketers that enhanced advertising ethics is a major component in building brand loyalty and trust with consumers? Most important, how do we inspire the millions of professionals in the advertising industry to practice the highest of personal ethics in their day-to-day advertising creation and dissemination to consumers? This article focuses on the answers to those questions, based on the professional experience I can bring to the table as one who has counseled the advertising industry over my entire career. I cite consumer research that I have been able to gather to establish how consumers define ethics in advertising and how important it is to them in their purchasing decisions. september 2011

it is reported that consumers rank advertising at

The Federal Trade Commission and the Department of Justice, fully appreciating the competitive benefit of advertising to the free market economy, have brought successful legal actions to prohibit its restraint by various professions, including doctors and dentists. The Supreme Court, concluding that commercial speech in many instances is more important to the public than political speech, held that truthful advertising is protected by the First Amendment to the Constitution. Virginia State Pharmacy Board v. Virginia Citizens Consumer Council, 425 U.S. 748 (1976)

DOI: 10.2501/JAR-51-3-477-483




A BRIEF FOR EnHAnCInG ADvERTISInG ETHICS In OUR ADvERTISInG InDUSTRY The Definition of Advertising Ethics with Five Illustrations of Unethical Practices In defining what constitutes ethical and unethical practices, we start with making sure we follow legal and regulatory standards. It would be impossible to be ethical without being truthful, and we have an obligation, as advertising practitioners, to know and follow government and industry self-regulatory standards. The Federal Trade Commission (FTC), the principle federal regulator of advertising, requires that advertisements must be substantiated by a prior reasonable basis of fact. Further, ads cannot omit material factsthe inclusion of which would render the ads misleading. The states have similar disclosure requirements.

in the eyes of children, from news content and from entertainment and games. This is a major ethical challenge that must be resolved on a case-by-case basis, depending on the manner in which the ad is designed and disseminated.

the ethical obligation to treat children fairly. Indistinct notions of Advertising The unethical blurring of the line between advertising, on the one hand, and editorial and entertainment, on the other, also is highly prevalent in advertisements directed to adults. This blurring has been a problem for a considerable amount of time. Walter Williams, dean of the Missouri School of Journalism (19081935), denounced this unethical practice in a speech given in 1919 to the Associated Clubs of Iowa: A newspaper cannot be independent in the opinion of the public if it carries advertising disguised as editorial comment or news. It is a species of dishonestyno less because it is sometimes practicedfor a newspaper to express pay opinions in disguised advertising and thereby deceive its readers. The readers have a right to demand frankness, as opposed to deception.4 Unfortunately, with the dramatic explosion of media sources, blurring of commercial and editorial content is more of an issue today than it was in Walter Williamss time. The concerns continue with advertising in the form of news articles, unsubstantiated claims in press releases, and unattributed commercial content on social networking sites, all of which have been the subject of regulatory or self-regulatory activity. A very topical illustration appeared on YouTube. Cardo Systems, the manufacturer of Wireless Bluetooth Headsets, ran a video showing individuals using their

The Childrens Advertising Review Unit (CARU) which monitors advertising and seeks voluntary compliance from marketers, recommends in its code that advertising should not be presented in a manner that blurs the distinction between advertising and editorial content, because children are especially vulnerable by virtue of their inexperience, immaturity, susceptibility to being misled or unduly influenced, and lack of cognitive skills to evaluate the credibility of advertising. Take the print ad for Tulip Glam-It Up! Iron-on Crystals marketed by Duncan Enterprises. This ad featured a young girl, and the concern was that to children this might be seen as an article about the girl as a fashion designer. CARU looked at the structure, content, and presentation of the ad. It recommended that the ad be clearly and conspicuously labeled, as such, in a manner that children would understand, taking into account their limited vocabularies and level of language skills (CARU News, 2010). Those crafting ads directed to children must make sureon a case-by-case basisthat children understand the persuasive nature of the ad. And they must understand that the game they are playing on the Internet is actually an advertisement. Those creating childrens ads have

Marketers spend considerable time and resources in complying with government laws and regulations guiding ad practices. Advertising ethics, however, must go a step above the law to ensure that consumers are treated appropriately. Protecting Children Advertising to children under the age of 12 is allowed in the United States but in few other countries. Where it exists, it needs to be held to high ethical standards because of the vulnerability of the audience. Also, we must be sure the children to whom we are addressing the ads understand the persuasive nature of advertising. Children are connected to products on TV, radio, print, and the Internet. Their points of engagements include advertisements on cell phones, G-rated DVDs and company-sponsored computer and video games and video. Moreover, advertisingin all instancesmust be clearly distinguished,

The Federal Trade Commission has an excellent business and legal section on its Web site

The issue of persuasion and advertising was the focus of the Childrens Advertising Rulemaking proceeding at the Federal Trade Commission back in 1978. The evidence showed that young children 7 years and younger did not understand the persuasive intent of advertising, whereas those children 8 to 12 did. This made it difficult to protect younger children because they were part of a larger TV audience of children that did in general understand persuasion. Rather than ban advertising to children, the issue now is whether children understand the persuasive intent on a case-by-case basis.

Walter Williams gave speeches exhorting truthfulness and honesty and concluding that The value of a newspaper as an advertising medium depends in large degree on the faith of the public in it. Collection 2533, Williams Speeches, folder 627, Western Historical Manuscript Collection-Columbia.



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cell phones to pop popcorn kernels in close proximity. Although the company argued that this was entertainment, the National Advertising Review Unit (the advertising industrys self-regulatory body) concluded that though Cardo never mentioned its name or product, this was, in fact, an ad claiming that cell phones emit heat and radiation, and it is dangerous to users without a separate head-set (National Advertising Review Commission [NARC], 2008). viral Messaging and User-Generated Content The proliferation of word-of-mouth marketing and blogging about commercial products and services creates special concerns about the blurring of advertising and editorial content. Marc Pritchard, Procter & Gamble global marketing officer, offers his own point of emphasis: Of particular concern is the need for advertisers to be transparent about the conditions for creating online endorsement, for example through bloggers or social media. It is often not clear [he believes] whether people are endorsing on their own, or if they are being compensated by a brand/company or are even part of the brand/company organization. Pritchard concludes, The anonymity of the online world requires extra efforts for practicing ethics (Pritchard, 2011). Pete Blackshaw, former chairman of the Council of Better Business Bureaus and current global head of digital marketing and social media at Nestl, observes, This area is going to get even more complicated in the months and years ahead. Disclosure with bloggers may well be the easy part. How do you responsibly disclose when 140 million global members of Twitter

prescription drug advertising that is directed to consumers (DtC) is another prime example of advertising requiring high ethics.

are restricted to 140 characters per tweet, and any attempts at disclosure gets lost in the first pass-along. Acknowledgeforcefullythat responsible advertisers must be extremely proactive on this front and perhaps even over-compensate (Blackshaw, 2011). We need to note that the FTC has taken action in this arena by amending its Endorsement and Testimonial Guides to require bloggers to disclose when they are being paid by a company, when they work for the company whose product is being blogged, and when they are given the product free of charge (FTC, 2009). Pharmaceutical Advertising Prescription drug advertising that is directed to consumers (DTC) is another prime example of advertising requiring high ethics. This is a major category of television and print advertising that is getting considerable attention from lawmakers, including many who wish to restrict itor even ban it. DTC has major potential benefits for consumers. After all, it can provide specific information about medical products and procedures available to treat the major illnesses we face. Further, the Food and Drug Administration has regulatory authority and requires that all appropriate warnings are provided in the particular advertising. Yet, consumers are raising considerable concerns about this advertising. For instance, research reported in Advertising Age found 39 percent of adults between the ages of 18 and 26 agreed with the

statement, I trust pharmaceutical companies less than I used to (Thomaselli, 2008). At the Institute for Advertising Ethics ethics forum in 2009 at the Missouri School of Journalism, Professor Glen Cameron urged that DTC ads must be allowed to be seen and heard. At first, he said, there will be healthy skepticism, but over time there will be a move to relevance. He also pointed out the importance of this advertising by referring to a study in North Carolina showing that a high percentage of consumers first learned of cervical cancer from DTC advertisements.5 The consumer concerns appear to be beyond the truthfulness of the claims. The nature of the product, itself, requires that the advertising be done in a serious manner. For instance, ads for anti-depressants carry very strong warnings, including the danger of suicide. Specific targeting to the audiences with specific maladies could be received with higher relevance and acceptance. This is difficult with mass marketing advertising, but ads with links to Web sites for more specific information are being used. The pharmaceutical industry has published a voluntary code for the advertising of DTC. This is commendable. I believe it would carry more credibility if the code were enforced by an independent,

An Interactive Panel DiscussionThe Importance of Advertising Ethics, Wednesday, October 24, 2009, Fred W. Smith Forum, Reynolds Journalism Institute, Missouri School of Journalism, University of Missouri www.

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third-party, regulatory body, such as the National Advertising Division. Behavioral Advertising Perhaps the greatest online opportunity for advertisersand a subject of keen controversy in the U.S Congress and with federal regulatorsis the segmentation of consumers via cookies placed on their computers according to the interests they express in online activities. The digital markers may include search queries, advertisements a consumer has clicked on, information they have shared on social sites, and products they have put in online shopping carts. Advertisers use this data to direct more specific ads to the consumer. This cuts down the cost of advertising even as it elevates the cost-effectiveness to consumers in getting the products and services they want. Yet, research shows that consumers fear that behavioral targeting infringes on their personal privacy. Also, consumers are not always aware of the information that is being collected, or how it is being used. Finally, consumers often cannot easily or effectivelyopt out of the collection process. All this has caused great concern from the government, with the Obama Administration, Congress, and the FTC all threatening the practice of behavioral advertising. In fact, in March 2011, President Barack Obama pushed Congress to pass an online privacy law. According to Advertising Age, A privacy law is sure to take shape in the coming months. Its not clear where advertising will land in the legislation (Lee, 2011). The most restrictive option under discussion would give a consumer a Do-Not-Track option thatif techno6

logically possiblewould severely restrict behavioral advertising. Also, the FTC brought a legal action against a company named Chitika that did not follow consumers decisions to opt out of behavioral advertising. Although

to maximize their access to relevant online advertising information and connections. And, as Tim Armstrong, AOL chairman/ CEO, believes, ethics can be established online through thousands of one on one dialogues with consumers where the consumer is helped.8 These five ethical opportunities will be with us well into our advertising future. Though government is involved, as one who both has regulated and counseled the industry, I believe the ad industry can best deal with them on a voluntary, ethical basis. Government regulation would be difficult, because of the technological complexities presented, and potentially over-restrictive. Consumers Want High Ethics in Advertising and Will Reward and Punish Companies Based on Ethics We start with the premise that consumers value high ethics in companies and are willing to pay for it. We know from research that consumers ranked ethics and values as the number-one factor in assessing whether a company can be called a corporate good citizen (Bozell Worldwide, 1996). And research reported in the Wall Street Journal showed that consumers are willing to pay more for an ethically produced product. Consumers were asked how much they were willing to pay for a pound of coffee depending on whether it was produced ethically or unethically. The group receiving information regarding ethical production was willing to pay significantly more than the control group. And the group receiving information regarding unethical production punished the company by saying they would pay

the company promised consumers they could opt outand provided an opt out button10 days after opting out, it reintroduced cookies on the consumers computers and again collected and used the data for advertising. The FTC found this to be a deceptive practice, and the company agreed to an order prohibiting misleading claims regarding how the consumer information was being used and in regard to opting out. Further, Chitika agreed to destroy the data collected illegally and to provide the consumers misled with the ability to easily opt out for a 5-year period. It is important to note that the FTC was able to detect and prove the deceptive conduct of the company. It is clear that the industry must conduct behavioral advertising in a transparent and ethical manner or risk the governments shutting down this important marketing initiative. Marketing and media trade associations are launching a new self-regulatory initiative that will give consumers enhanced control over the collection and use of Web data (AAF, 2010). The program promotes the use of an Advertising Option Icon and accompanying languageto be displayed in behaviorally targeted ads and on Web pages where behavioral data are collected. By clicking on the icon, consumers will receive a clear disclosure regarding the use of their online data and also be able to easily opt out of such collection. Advertisers that practice enhanced ethics will provide consumers with the ability

PhRMA Guiding Principles Direct to Consumer Advertising about Prescription Medicines

In the Matter of Chitika, Inc., a corporation, FTC File No. 1023087, March 21, 2011

Interactive Panel Discussion on Advertising Ethics, October 24, 2009



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far less than the control group (Trudel and Cotte, 2008). The high impact of advertising ethics was demonstrated in consumer research conducted by four Capstone student teams in 2009 at the Missouri School of Journalism. Collectively, the groups studied the beliefs of consumers, marketers, and advertising majors. The primary research consisted of online surveys with follow-up interviews. Though not representative, the work shows beliefs and attitudes that are consistent and instructive. The research found that Honest Advertising was the top-ranked aspect that would make a company ethical (89 percent) with consumers, followed by being Socially Responsible (80 percent) and Environmentally Friendly (59 percent). For advertising to be associated with socially responsible marketing and positive environmental initiatives is noteworthy, considering how much companies devote in spending annually to the latter two. We need to reinforce with marketers just how much important honest advertising is in contributing to their ethical standing with consumers. Advertisers must recognize that though consumers tell us they want honest and ethical advertising, they do not believe they are getting it. The latest research from the Adweek Media/Harris Poll shows that only one in five Americans trust advertising most of the time and 13 percent say they never trust it. The large group of 65 percent in the middle, who say they trust advertising some of the time, presents the opportunity for us to build brand and corporate trust through enhanced ethical advertising (Adweek media/Harris Poll, November 8, 2010. Harris interactive http://www. The online explosion of communications has placed consumers in control of

Advertisers must recognize that though consumers tell us they want honest and ethical advertising, they do not believe they are getting it.

the commercial information they want and how they wish to receive it. Consumers have the power to share information about the productsand adsthat they like and dislike. An impactful illustration is the Web site created by EnviroMedia where consumers go to rate the credibility of green marketing claims. Hundreds of ads have been available to rate, and some have received very highand some very lowratings. Take the billboard ad in Pennsylvania that touted coal as a clean energy source. It received a very poor rating.

The ad immediately was attacked by thousands of consumers for making light of Tibetans hardships on social networking sites across the internet. Groupon CEO Andrew Mason pulled the ad 5 days later. Then, after another week, he commented that he placed too much trust in the agency to be edgy, informative and entertaining, and we turned off the part of our brain where we should have made our own decisions. We learned that you cant rely on anyone else to control and maintain your own brand (Parekh, 2011). In fact, it is the role of the ad agency to develop trust for the brand. That trust, however, cannot be built by advertising that is viewed as improper or unethical by the consumer. The Capstone student research found that marketing professionals believed that the greatest benefit from advertising ethics is in building consumer trust.10 Professionals in the Business of Advertising Will Practice Enhanced Personal Ethics if Given Appropriate Guidelines and Reinforcement The Institute for Advertising Ethics in 2011 published online Principles and Practices for Advertising Ethics that provide the guidelines to practice high personal

Also, consumers share daily their likes and dislikes on social media, including YouTube, MySpace, and Facebook. A 2011 illustration is the television spot for that appeared in this years Super Bowl. Groupon is a very influential Web site that focuses in distributing coupons to consumers in local markets across the nation. The spot featured actor Timothy Hutton in what appeared to be a public service advertisement (PSA) to aid hurting Tibetans when he stated, The people of Tibet are in trouble, their very culture is in jeopardy. Then, without a pause, he went on, But they still whip up an amazing fish curry, and since 200 of us bought at, were each getting $30 worth of Tibetan food for just $15 at Himalayan Restaurant in Chicago.

Greenwashing Index, promoted by EnviroMedia Social Marketing and the University of Oregon

10 Of the marketers surveyed in the Capstone student research, 53 percent responded that ethics is very important to professionals. Building consumer trust was seen by 43 percent of the sample as the greatest benefit from advertising ethics.

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ethics.11 Included with each of the eight principles and practices is commentary with links to government, industry and self-regulation sites that provide clarity and illustrations of the ethical issues that most concern consumers. Clients, agencies, media companies, and suppliers can utilize the principles and commentary in their internal consideration of ethical advertising issues. There should always be the expectation that advertising ethics will be considered proactively by advertising professionals. And, the mandate must be from the top down and run all through the company. A private and internal ethics discussion would have saved many clients from having to pull ads attacked by consumers (e.g., the Groupon Super Bowl ad discussed earlier in this paper). In my classes on ethics, I have requested students to express their ethical concerns about particular ads. For instance, I asked creative classes their views on a print public service announcement (PSA) run with the good intention of getting young people to vote for the first time in the last presidential election. The PSA depicted a young woman silenced and tied up with duct tape. Several expressed concern that the ad as created actually depicted violence against womenand therefore the PSA message would be rejected by women. In role playing, I asked whether they would express those concerns to meas the account executivebefore I talked with the client. The answer was, Yes, if you give me permission. Holding internal ethics discussions and giving permission to express ethical concerns is essential. These discussions have
11 The Institute for Advertising Ethics principles and practices with commentary can be downloaded by going to the Web site of the American Advertising Federationwww. aaf.organd the Web site of the Reynolds Journalism

to take place in the fast-paced and competitive world of advertising creation and placement. Yet, we must take the time to resolve ethical dilemmas. We can learn from Rushworth Kidders book on ethics, How Good People Make Tough Choices, where he states, Youve got to think about it, reason it through, get the mind in gear and grapple with the tough issues. In other words, youve got to be mentally engaged (Kidder, 2009). There is no doubt that ad professionals face tough choices in exercising their personal ethics. They can follow the guidance and beliefs of top adverting executives, who emphasize the importance of personal ethics. For instance, Tim Love, Omnicom Group of Agencies vice chairman, urges professionals to Question the source of their information; we have alternative sources and choices we can make. They also provide counsel for what to do when you do not want to do what your boss says because of your personal ethics. David Bell, chair of Gyro International, and chair emeritus of the Interpublic Group of agencies advices, Say no and present an alternate ethical solution.12 The companies that practice and rely upon advertising must play a major role in requiringand inspiringtheir professionals to apply the highest personal ethics in their work product. The motivator will be the power this brings to building brand and corporate value. Though I believe that proposition has been established, certainly additional research into the more precise understanding consumers have regarding ad ethics would reinforce company ethical behavior. The advertising companyand its leadershipplay a critical role in establishing the expectation that enhanced ad ethics

always will be expected and that its professionals have permission to express internally their ethical concerns. When it comes right down to it, the role of professionals is central to the practice of high ethical standards by their companies. The importance of advertising to consumers and the economy can stimulate professionals to practice the highest levels of personal ethics. When you believe in what you do when you know how important your work ityou want to do your best in carrying out your responsibilities. Veteransand young advertising leadersare stepping forward to make the case for practicing enhanced advertising ethics. Jeff Levick, the winner of a 2010 Advertising Hall of Achievement Award, states, Its critical for the industry to acknowledge and accept that advertising is commercial information that must be treated with the same accuracy and ethics as editorial information. And Adam Werbach, the chief sustainability officer for Saatchi and Saatchi, urges, As new professionals enter the advertising world it is imperative that they are aware of the importance of high ethics to their consumers and careers.13 CALL TO ACTIOn This paper presents my case for enhanced advertising ethics. Specifically: First, I have documented unethical illustrations that are important to consumers. Second, I have presented evidence that consumers say they will reward ethical ads and punish unethical ones. This leads to my third, and concluding point that advertising professionals will practice enhanced personal ethics if given appropriate ethical


Interactive Panel Discussion on Advertising Ethics, October 24, 2009

Commentary, Institute for Advertising Ethics Principles and Practices for Advertising Ethics



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guidelines and reinforcement within their companies. The advertising industry and its professionals need a new way of thinking about advertising ethics. Not just, I know it is important and we should do it. Not just, I tell my employees that they should be ethical. As a company leader, however, I want my professionals to practice the highest advertising ethics to build the highest brand loyalty and company value. And, as a professional in this important industry, I want to practice the highest level of ethics in my business dealings. I want to do what is best for the consumer. I know that if I always follow my conscience in doing what is right I will benefit my company, my career, and my industry. We can all play a major role in raising the bar on advertising ethics. As academics we can insure that our advertising students are exposed to why advertising ethics is important, how they can practice the highest ethics, and what are the critical ethical issues to consumer welfare. As clients, agencies, media, and suppliers, we can create the ethical atmosphere and internal processes that will enable our professionals to consider and act upon ethical issues. We all must believe in the value of our mission and all work toward our most important objective: to inspire our advertising professionals to practice and benefit from enhanced advertising ethics.

their professionals members; and the students and professors in 226 college chaptersfrom 1992 to 2008. He headed government relations for the association members between 1985 and 1991. Prior to his AAF work, he served as a lawyer for the Federal Trade commission from 1969 to 1985, first as a trial attorney and then as associate director for advertising practices. snyder now serves as executive director of the newly founded Institute for Advertising Ethics, a partnership of the AAF and the Missouri school of Journalism and the university of Missouris Reynolds Journalism Institute.

Testimonials, October 10, 2009. Retrieved June 10, 2011, from opa/2009/10/endortest.shtm Jones, JeFFrey m. Lobbyists Debut at Bottom of Honesty and Ethics List. Gallup, December 10, 2007. Kidder, rUsHwortH H. How Good People Make Tough Choices. New York: Harper, 2003. lee, edmUnd. Online Self-Regulation May Not Satisfy Obama Administration. Advertising Age, March 21, 2011. Retrieved June 12, 2011 from obama-online-advertising-regulation/149493/ national advertisinG review coUncil.

aaF. Major Marketing/Media Trade Groups Launch Program to Give Consumers Enhanced Control over Collection and Use of Web Viewing Data for Online Behavioral Advertising, October 4, 2010, http:// adweeK
media /H arris

Case Report #4934, Cardo SystemsWireless Bluetooth Headsets. November 14, 2008. Retrieved July 15, 2011, from www.narbreview. org



8, 2010. Harris interactive. Retrieved from BlacKsHaw, Pete. Principles and Practices for Advertising Preamble: Commentary. Retrieved July 15, 2011, from http://www. Bozell worldwide. Global Corporate Citizenship: Improving Perceptions in the 90s. The Wall Street Journal International Edition and the Nihon Keizai Shimbun Bozell, 1996. carU news. Caru Recommends Duncan Enterprises Discontinue Certain Claims For Glam-It-Up! Iron-On Crystals, January 13, 2010. Retrieved June 10, 2011, from http:// Federal trade commission. FTC Pub-

PareKH, rUPal. Groupon CEO: We Placed Too Much Trust in Agency for Super Bowl Ads. Advertising Age, March 21, 2011. Retrieved June 12, 2011, from groupon-ceo-relied-agency-bowl-ads/149498/ PritcHard, marc. Principles and Practices for Advertising Preamble: Commentary retrieved July 15, 2011, from http://www. tHomaselli, ricH. Pharma Biz Cops to $5 Billion Drug Problem. Advertising Age, January 28, 2008. Retrieved June 12, 2011, from http:// trUdel, remi, and JUne cotte. Corporate Reputation: Does Being Ethical Pay? Wall Street Journal, May 12, 2008. Retrieved June 12, 2011, from SB121018735490274425.html

WaLLy snyder, executive director of the Institute for Advertising Ethics, is president emeritus of the American Advertising Federation. He served as president and cEO of the American Advertising Federationthe ad association serving nearly 100 national clients, agencies, media companies; 200 local ad clubs and

lishes Final Guides Governing Endorsements

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